Bonilla v. Greth
- Phyllis Hamilton
- 4:25-cv-05300
- U.S. District Court · Northern District of California
- 3
Bonilla v. U.S. District Judges and Court Clerks: Judge Hamilton dismissed multiple cases with prejudice after finding no imminent danger and other legal bars.
Steven Wayne Bonilla, whose multiple civil-rights cases were dismissed with prejudice and closed; the named federal and state courts and government agencies were the defendants in those cases.
What happened
In Steven Wayne Bonilla v. U.S. District Court Northern District Judges and Court Clerks et. al., a state prisoner filed multiple nearly identical civil-rights lawsuits without a lawyer. He sued various federal and state courts and government agencies and sought relief related to his conviction or the handling of his other cases.
The court found that Bonilla could not proceed without paying filing fees because he did not show that he faced imminent danger of serious physical injury when he filed. The court also said that, even if he had been allowed to proceed without paying, the lawsuits would be barred under several legal rules. It dismissed the cases with prejudice.
Judge Phyllis J. Hamilton ordered the clerk to terminate all pending motions and close the cases. She also directed the clerk to return without filing any further documents Bonilla submits in the closed cases and concluded that the repetitive filings did not create a reasonable question about her impartiality.
The detailed version
- Bonilla v. Greth · No. 4:25-cv-05300
- Phyllis Hamilton
- June 30, 2025
Background
Steven Wayne Bonilla, a state prisoner who is described as condemned, filed multiple nearly identical complaints under 42 U.S.C. § 1983, the federal civil-rights statute used to sue for certain violations by government officials acting under state law. He filed the actions without a lawyer. The complaints named various federal and state courts and government agencies as defendants and sought relief related to Bonilla’s underlying conviction or the handling of his other cases.
The order notes 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. The order also states that he had an extensive history of filing similar cases.
Court’s analysis
The court addressed whether Bonilla could proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without payment may do so only if the complaint shows that the prisoner was in imminent danger of serious physical injury when it was filed. The court found that Bonilla’s allegations did not show imminent danger, so he could not proceed without paying the fees.
The court further stated that, even if an application to proceed without paying the fees 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 order did not provide separate claim-by-claim analysis of those rules.
Ruling and 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 ordered to return, without filing, any further documents Bonilla submits in the closed cases.
Judge Phyllis J. Hamilton also rejected the apparent concern that the repetitive and frivolous filings required her recusal. She stated that these cases were not ones in which her impartiality might reasonably be questioned and cited the principle that, absent legitimate reasons for recusal, an assigned judge has a duty to decide the cases assigned to that judge.
Classification
This is a procedural order because the court disposed of the cases based on the prisoner-filing-fee restriction and other threshold legal bars without deciding the underlying civil-rights claims on their merits.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.