Bonilla v. Federal Bureau of Investigation
- Phyllis Hamilton
- 4:25-cv-04894
- U.S. District Court · Northern District of California
- 3
In Bonilla v. U.S. District Judges, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla did not show imminent danger and the claims were barred.
Steven Wayne Bonilla and the defendants in the multiple cases; all listed cases were dismissed with prejudice and closed.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple similar cases without a lawyer under a federal civil-rights law. He challenged his conviction and the handling of his other cases, naming various federal and state courts and government agencies as defendants.
The court found that Bonilla could not proceed without paying filing fees because he had not shown that he faced an immediate danger of serious physical injury when he filed. The court also said that, even if that status were granted, legal rules barred the lawsuits. It dismissed the cases with prejudice, closed them, terminated all pending motions, and directed the clerk to return future documents submitted in those cases without filing them.
Judge Phyllis J. Hamilton also rejected the suggestion that the repetitive filings required her to step aside. The order was entered on June 30, 2025.
The detailed version
- Bonilla v. Federal Bureau of Investigation · No. 4:25-cv-04894
- Phyllis Hamilton
- June 30, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical complaints without a lawyer under 42 U.S.C. § 1983, a statute that allows certain civil-rights claims against state actors. He named various federal and state courts and government agencies as defendants. The complaints sought relief concerning his underlying conviction or the way his other state and federal cases had been handled.
The court noted that Bonilla had a pending federal petition challenging his custody in the same court, with appointed counsel, and was represented by counsel in state-court proceedings concerning his custody. The opinion did not resolve those other proceedings.
Reasons for dismissal
The court stated that, to the extent Bonilla sought permission to proceed in forma pauperis (IFP), meaning without paying the usual filing fees in advance, 28 U.S.C. § 1915(g) barred that status unless he showed that he was in imminent danger of serious physical injury when he filed. The court found that the complaints did not make that showing.
The court further stated that, even if an IFP application were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order did not separately analyze each complaint or explain which cited rule applied to which case. Based on those reasons, the court dismissed the cases with prejudice.
Other rulings and case closure
The court stated that the repetitive and frivolous nature of the filings did not create a reasonable basis to question Judge Phyllis J. Hamilton’s impartiality. The clerk was ordered 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 noted that Hamilton was the fourth judge assigned to Bonilla’s cases and that, since April 30, 2020, she had issued 76 orders concerning 1,116 different cases filed by him. The court also stated that Bonilla had filed 962 other cases with three other judges since 2011.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.