Bonilla v. Lovrin
- Phyllis Hamilton
- 4:25-cv-04376
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Lovrin, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims faced legal barriers.
Steven Wayne Bonilla and the five related civil-rights cases identified by the court; the order also affects any pending motions and future documents submitted in those closed cases.
What happened
Bonilla v. Lovrin involved multiple cases filed by Steven Wayne Bonilla, who challenged his conviction and the handling of his other state and federal court cases. Judge Hamilton’s order addressed five related case numbers.
Bonilla, a state prisoner, filed the complaints without a lawyer under a federal civil-rights law. He named various federal and state officials and sought relief connected to his conviction and other litigation. The opinion says the complaints were nearly identical and that Bonilla had appointed counsel in a pending federal habeas case and counsel in state habeas proceedings.
The court said Bonilla was barred from proceeding without paying the filing fees unless he showed an immediate risk of serious physical injury, and that his allegations did not make that showing. Judge Hamilton also said the lawsuits would be barred by several other legal doctrines even if his applications were granted. The court dismissed all five cases with prejudice, terminated pending motions, closed the cases, and directed the clerk to return future filings without filing them.
The detailed version
- Bonilla v. Lovrin · No. 4:25-cv-04376
- Phyllis Hamilton
- May 28, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed five nearly identical civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints named various federal and state officials. Bonilla sought relief concerning his underlying conviction and the handling of his other state and federal court cases.
The order states that Bonilla had a pending federal petition challenging his imprisonment in the same district, with appointed counsel, and that he was represented by counsel in state habeas proceedings. The court also noted his extensive history of filing similar cases and stated in a footnote that it was the fourth judge assigned to his cases and that these were the 75th such cases filed by him.
Court’s reasoning
The court addressed Bonilla’s possible requests to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the relevant qualifying dismissals generally may proceed without prepaying fees only if he was in imminent danger of serious physical injury when he filed the complaint. The court stated that Bonilla had been disqualified from proceeding without prepayment under that statute unless he met that exception, and that his allegations did not show imminent danger.
The court further stated that, even if Bonilla’s applications to proceed without prepaying fees were granted, the lawsuits would be barred under the legal doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order does not provide a separate merits analysis of each complaint’s claims.
Disposition
Judge Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. The opinion’s text contains a line break that leaves part of the discussion of imminent danger incomplete, but the stated dismissal and other directions are clear.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.