Steven W. Bonilla v. Judge Anthony J. Battaglia
- Phyllis Hamilton
- 4:25-cv-06277
- U.S. District Court · Northern District of California
- 4
In Steven Wayne Bonilla v. Alameda County Superior Court, Judge Hamilton dismissed multiple cases with prejudice because Bonilla could not proceed without paying filing fees and his claims were barred.
Steven Wayne Bonilla’s multiple pro se Section 1983 cases were dismissed with prejudice and closed. The order also terminated pending motions and barred him from proceeding in those cases without paying filing fees.
What happened
In Steven Wayne Bonilla v. Alameda County Superior Court, Bonilla, a state prisoner representing himself, filed multiple civil-rights cases under a federal law known as Section 1983. He sued various federal judges, state judges, and state courts over his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying filing fees because he had previously been barred from that option and had not shown an immediate danger of serious physical injury when he filed. The court also said that, even if he had been allowed to proceed without those fees, the lawsuits were barred by several legal rules. It dismissed the cases with prejudice, terminated all pending motions, and closed the cases.
Judge Phyllis J. Hamilton issued the order on August 20, 2025. She also ruled that the repetitive and allegedly frivolous filings did not provide a reason to question her impartiality. The clerk was directed to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Steven W. Bonilla v. Judge Anthony J. Battaglia · No. 4:25-cv-06277
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple pro se civil-rights complaints under 42 U.S.C. § 1983. The complaints named various federal judges, state judges, and state courts as defendants. They presented nearly identical claims concerning Bonilla’s underlying conviction or the way his other cases had been handled by state and federal courts.
The order identifies Bonilla as a condemned prisoner who has a pending federal habeas petition in the Northern District of California with appointed counsel. It also states that he is represented by counsel in state-court habeas proceedings.
Filing-fee determination
To the extent Bonilla sought permission to proceed in forma pauperis, meaning without paying the filing fee, the court held that 28 U.S.C. § 1915(g) barred him from doing so unless he was under imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger. It therefore held that Bonilla could not proceed in forma pauperis in these cases.
Dismissal
The court further ruled that, even if an application to proceed in forma pauperis 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 order does not provide a separate claim-by-claim analysis of which cited rule applies to which complaint. It concludes: “Accordingly, the cases are dismissed with prejudice.”
Dismissal with prejudice means the order bars refiling the dismissed cases. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases.
Impartiality and final orders
The court also stated that the repetitive and frivolous nature of the filings did not create a reasonable question about the undersigned judge’s impartiality. The order notes that Bonilla named Judge Hamilton as a defendant in four of the cases but made no specific allegations against her. Judge Hamilton signed the order on August 20, 2025.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.