Bonilla v. McElfresh
- Phyllis Hamilton
- 4:25-cv-02533
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Villarreal, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and identifying additional legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. All pending motions were terminated, the cases were closed, and future documents submitted in those cases were to be returned without filing.
What happened
In Bonilla v. Villarreal, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights complaints under federal law. He challenged his conviction or the way state and federal courts handled his other cases and named various judges and officials as defendants.
The court ruled that Bonilla could not proceed without paying the filing fees because his allegations did not show that he faced imminent danger of serious physical injury when he filed. The court also said that, even if he could proceed without paying, the cases were barred by other legal rules. It dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close them.
Judge Phyllis J. Hamilton also stated that the repetitive and frivolous nature of Bonilla’s filings did not provide a reasonable basis to question her impartiality. The clerk was directed to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. McElfresh · No. 4:25-cv-02533
- Phyllis Hamilton
- Mar. 27, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal law allowing certain civil-rights claims against government officials. The complaints presented nearly identical claims against various federal and state judges and other officials. Bonilla sought relief concerning his underlying conviction or the handling of his other state and federal court cases. The order states that he has appointed counsel in a pending federal petition challenging his detention and counsel in state-court proceedings.
Filing-fee restriction
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when each complaint was filed. The court found that the allegations did not show such danger. Therefore, Bonilla could not proceed without paying the filing fee.
Other legal bars and disposition
The court further ruled that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under legal rules identified in the order, including rules concerning challenges to criminal convictions, interference with ongoing proceedings, and certain claims against federal courts. The court dismissed the cases with prejudice. The order does not analyze the underlying merits of Bonilla’s claims.
Additional rulings
The court stated that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the undersigned judge’s impartiality. The clerk was ordered to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submits in those closed cases.
Judge
The order was signed by United States District Judge Phyllis J. Hamilton on March 27, 2025.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.