Bonilla v. Simmons
- Phyllis Hamilton
- 4:25-cv-02532
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Judge Lydia Villarreal, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because filing restrictions and other legal bars applied.
Steven Wayne Bonilla’s multiple related civil-rights cases were dismissed with prejudice; pending motions were terminated, the cases were closed, and future submissions in those cases were to be returned without filing.
What happened
In Bonilla v. Judge Lydia Villarreal et al., Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against judges and other officials. He challenged his conviction and how his other cases had been handled.
The court said Bonilla could not proceed without paying the filing fees because his prior cases disqualified him from that status, and his complaints did not show an immediate risk of serious physical harm. The court also said the lawsuits would be barred by several other legal rules even if that status were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return future documents submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Simmons · No. 4:25-cv-02532
- Phyllis Hamilton
- Mar. 27, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints representing himself under 42 U.S.C. § 1983, the federal law that allows certain civil-rights claims against state actors. The opinion lists numerous related case numbers, including 25-cv-1979-PJH and 25-cv-1980-PJH. The complaints were nearly identical and named various federal and state judges and other officials. Bonilla sought relief concerning his underlying conviction or the handling of his other cases in state and federal courts.
The court noted that Bonilla had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings. The opinion also stated that he had an extensive history of filing similar cases.
Filing-fee restriction
To the extent Bonilla sought permission to proceed without paying the filing fee, the court held that 28 U.S.C. § 1915(g) disqualified him from doing so unless he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such imminent danger. Therefore, Bonilla could not proceed under that fee-waiver status.
Other legal bars
The court further stated that, even if Bonilla’s application to proceed without paying the filing fee were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not resolve the underlying challenges to Bonilla’s conviction or the handling of his other cases.
Ruling and case closure
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in those closed cases.
The court additionally stated that the repetitive and allegedly frivolous nature of the filings did not provide a reasonable basis to question the undersigned judge’s impartiality. Judge Phyllis J. Hamilton signed the order on March 27, 2025.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.