Bonilla v. San Joaquin County Superior Court
- Phyllis Hamilton
- 4:25-cv-05248
- U.S. District Court · Northern District of California
- 3
In Bonilla v. U.S. District Court Northern District Judges, Judge Hamilton dismissed multiple lawsuits with prejudice after finding no imminent danger and applying other legal bars.
Steven Wayne Bonilla’s listed lawsuits were dismissed with prejudice, the pending motions were terminated, and the cases were closed; the defendants in those cases were not required to litigate the claims further.
What happened
In Steven Wayne Bonilla v. U.S. District Court Northern District Judges and Court Clerks et al., Bonilla, a state prisoner, filed multiple civil-rights lawsuits without a lawyer. He challenged his conviction and how state and federal courts handled his other cases.
The court said Bonilla could not proceed without paying the filing fee because his allegations did not show that he faced imminent danger of serious physical injury when he filed the complaints. The court also said that, even if he had received permission to proceed without paying, legal rules would bar the lawsuits.
The court dismissed the cases with prejudice, ended all pending motions, and ordered the clerk to close the cases and return future filings in them without filing them. Judge Phyllis J. Hamilton also declined to recuse herself because the filings did not reasonably question her impartiality.
The detailed version
- Bonilla v. San Joaquin County Superior Court · No. 4:25-cv-05248
- Phyllis Hamilton
- June 30, 2025
Background
Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a civil-rights statute. The complaints presented nearly identical claims against various federal and state courts and government agencies. They sought relief concerning Bonilla’s underlying conviction or the way his other state and federal cases had been handled.
The opinion states that Bonilla is a condemned prisoner who has a pending federal petition challenging his detention with appointed counsel. It also states that he is represented by counsel in state proceedings challenging his detention.
Filing-Fee Determination
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 a disqualified prisoner to proceed without paying only if the prisoner was in imminent danger of serious physical injury when the complaint was filed. The court found that the allegations did not show such danger, so Bonilla could not proceed without paying the filing fee.
Other Grounds for Dismissal
The court further ruled that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion therefore did not allow the cases to proceed to adjudication of Bonilla’s underlying claims.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases.
The court also addressed whether Judge Phyllis J. Hamilton should recuse herself because of the repetitive and allegedly frivolous filings. It concluded that the circumstances did not reasonably call her impartiality into question and did not require recusal.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.