Bonilla v. Casse
- Phyllis Hamilton
- 4:25-cv-02539
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Villarreal, Judge Hamilton dismissed the cases with prejudice because Bonilla could not proceed without paying fees and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. All pending motions were terminated, the cases were closed, and further documents submitted by Bonilla in those closed cases were to be returned without filing. The named defendants were not required to litigate these cases further.
What happened
In Steven Wayne Bonilla v. Judge Lydia Villarreal et al., Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against judges and other officials. He sought relief concerning his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fees because he had previously been disqualified from proceeding without fees, and his allegations did not show that he faced imminent danger of serious physical injury when he filed. The court also said the lawsuits would be barred by several legal doctrines even if his fee applications were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Casse · No. 4:25-cv-02539
- Phyllis Hamilton
- Mar. 27, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The complaints were nearly identical. They named various federal and state judges and other officials and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases by state and federal courts. The opinion also states that Bonilla had a pending federal petition challenging his detention with appointed counsel and was represented by counsel in state-court proceedings.
Proceeding Without Paying Filing Fees
The court explained that Bonilla had been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show imminent danger at the time of filing. Bonilla therefore could not proceed without paying the fees.
Other Bars Identified by the Court
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the principles identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion does not separately analyze which of those principles applied to each individual lawsuit.
Ruling and Case Closure
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in the closed cases.
The court additionally rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The opinion states that the undersigned judge was the fourth judge assigned to Bonilla’s cases and had issued the 74th order concerning 1,090 different cases filed by him since April 30, 2020.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.