Bonilla v. California Court of Appeal Sixth Appellate District
- Phyllis Hamilton
- 4:25-cv-02621
- U.S. District Court · Northern District of California
- 3
Bonilla v. Villarreal: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the order also terminated pending motions, closed the cases, and directed the clerk not to file further documents submitted in them.
What happened
In Steven Wayne Bonilla v. Judge Lydia Villarreal et al., a state prisoner filed multiple similar civil-rights lawsuits without a lawyer against judges and other officials. He sought relief concerning his conviction and how other state and federal court cases were handled.
The court said Bonilla was barred from proceeding without paying the filing fee unless he showed an immediate danger of serious physical injury when he filed. The complaints did not show that danger. The court also said that, even if he could proceed without paying, the lawsuits were barred by several legal doctrines concerning challenges to convictions, ongoing state proceedings, and interference with other courts.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases. The court also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive filings.
The detailed version
- Bonilla v. California Court of Appeal Sixth Appellate District · No. 4:25-cv-02621
- Phyllis Hamilton
- Mar. 27, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple similar civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The defendants included various federal and state judges and other officials. The complaints sought relief concerning Bonilla’s underlying conviction or the handling of his other cases in state and federal courts.
The order covers multiple cases, including Case Nos. 25-cv-1979-PJH, 25-cv-1980-PJH, 25-cv-2063-PJH, 25-cv-2064-PJH, 25-cv-2065-PJH, 25-cv-2178-PJH, 25-cv-2179-PJH, 25-cv-2180-PJH, 25-cv-2182-PJH, 25-cv-2183-PJH, 25-cv-2184-PJH, 25-cv-2444-PJH, 25-cv-2445-PJH, 25-cv-2513-PJH, 25-cv-2532-PJH, 25-cv-2533-PJH, 25-cv-2535-PJH, 25-cv-2536-PJH, 25-cv-2537-PJH, 25-cv-2538-PJH, 25-cv-2539-PJH, 25-cv-2540-PJH, 25-cv-2617-PJH, 25-cv-2618-PJH, 25-cv-2621-PJH, 25-cv-2629-PJH, 25-cv-2629-PJH, 25-cv-2532-PJH, 25-cv-2533-PJH, and 25-cv-2535-PJH, as well as the other case numbers listed in the order.
Reasoning
The court explained that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute permits such a prisoner to proceed without paying only if the complaint shows that the prisoner was under imminent danger of serious physical injury when the complaint was filed. The court found that these complaints did not show imminent danger.
The court further held that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order states that these doctrines barred the lawsuits but does not separately explain which doctrine applied to which case or claim.
The court also addressed judicial impartiality. It concluded that the repetitive and allegedly frivolous nature of the filings did not provide a reasonable basis to question the assigned judge’s impartiality. The order noted that the undersigned judge was the fourth judge assigned to Bonilla’s cases and had issued the 74th order concerning Bonilla’s filings since April 30, 2020, involving 1,090 different cases.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.