Bonilla v. Federal Bureau of Investigations
- Phyllis Hamilton
- 4:25-cv-04658
- U.S. District Court · Northern District of California
- 3
Judge Hamilton dismissed Bonilla v. U.S. District Judges with prejudice because the complaints did not meet filing requirements and were legally barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice and closed. The order also prevents further documents submitted in those closed cases from being filed.
What happened
In Bonilla v. U.S. District Judges and Court Clerks, Steven Wayne Bonilla, a state prisoner filing without a lawyer, brought multiple nearly identical civil-rights cases against federal and state courts and government agencies. He sought relief concerning his conviction and how other courts handled his cases.
The court found that Bonilla could not proceed without paying the filing fees because his allegations did not show an immediate threat of serious physical injury when he filed. The court also said the lawsuits were barred for several legal reasons, including rules protecting criminal judgments and limiting federal interference with ongoing cases.
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. Federal Bureau of Investigations · No. 4:25-cv-04658
- Phyllis Hamilton
- June 30, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints presented nearly identical claims and named various federal and state courts and government agencies as defendants. Bonilla sought relief related to his underlying conviction and the handling of his other state and federal cases.
The opinion also states that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings concerning his custody.
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). That restriction allows such a prisoner to proceed without paying only if he shows that he was facing an imminent danger of serious physical injury when he filed the complaint.
The court found that the allegations did not show imminent danger at the time of filing. It therefore concluded that Bonilla could not proceed without paying the filing fee.
Other legal bars
The court further stated that, even if Bonilla's applications 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 separately analyze each of those legal bars in detail. It also noted Bonilla's extensive history of filing similar cases.
The court rejected the suggestion that the assigned judge's impartiality could reasonably be questioned because of the repetitive and frivolous filings. The opinion stated that, absent legitimate grounds for disqualification, a judge has a duty to hear cases assigned to that judge.
Disposition
The court dismissed the cases with prejudice. The clerk was ordered 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.
The order was signed by United States District Judge Phyllis J. Hamilton on June 30, 2025.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.