Bonilla v. Wilken
- Phyllis Hamilton
- 4:25-cv-06269
- U.S. District Court · Northern District of California
- 4
In Bonilla v. Alameda County Superior Court, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice after finding no imminent danger and applying procedural bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the court also terminated pending motions, closed the cases, and directed the clerk not to file further documents submitted in them.
What happened
In Bonilla v. Alameda County Superior Court et al., a state prisoner filed multiple similar civil-rights complaints without a lawyer. He challenged his conviction and the handling of other cases by federal and state courts, naming judges and courts as defendants.
The court found that he could not proceed without paying the filing fee because his allegations did not show imminent danger of serious physical injury. The court also said that, even if he could proceed without paying, the lawsuits were barred by several legal rules, including rules concerning challenges to convictions, ongoing state proceedings, and lawsuits against federal courts.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return any further documents submitted in them without filing them.
The detailed version
- Bonilla v. Wilken · No. 4:25-cv-06269
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple similar complaints under 42 U.S.C. § 1983, the federal law that allows certain civil-rights lawsuits against state actors. He proceeded without a lawyer in these cases. The defendants included various federal judges, state judges, and state courts. The complaints sought relief related to Bonilla’s underlying conviction and the handling of his other cases by state and federal courts.
The opinion states that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel and was also represented by counsel in state court proceedings.
Court’s analysis
The court addressed Bonilla’s request, to the extent he sought to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally cannot proceed without paying unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court concluded that these complaints did not show such imminent danger.
The court further stated that, even if an application to proceed without paying had been 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 also noted Bonilla’s extensive history of filing similar cases.
The court rejected any suggestion that the judge’s impartiality could reasonably be questioned merely because of the repetitive and frivolous nature of the filings. The opinion noted that Bonilla named the judge as a defendant in four of the cases but made no specific allegations against her in those cases.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.
The opinion does not separately identify the disposition of each individual complaint or claim beyond stating that the cases were dismissed with prejudice.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.