Bonilla v. Hanson
- Phyllis Hamilton
- 4:25-cv-06280
- U.S. District Court · Northern District of California
- 4
In Steven Wayne Bonilla v. Alameda County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and other legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The defendants named in those cases were various federal judges, state judges, and state courts.
What happened
In Steven Wayne Bonilla v. Alameda County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed many nearly identical civil-rights lawsuits against federal judges, state judges, and state courts. His complaints sought relief concerning his conviction and the handling of his other cases.
The court found that Bonilla could not proceed without paying the filing fees because he had previously been barred from proceeding without fees unless he faced imminent danger of serious physical injury. The complaints did not show such danger. The court also stated that, even if he had been allowed to proceed without fees, the lawsuits would be barred by other legal rules.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases. The clerk was also directed to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Hanson · No. 4:25-cv-06280
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute that allows claims against state actors for violations of federal rights. He represented himself in these cases. The complaints were nearly identical and named various federal judges, state judges, and state courts as defendants. They sought relief concerning Bonilla’s underlying conviction or the handling of his other cases in state and federal court.
The opinion states that Bonilla had a pending federal petition concerning his imprisonment in this court, with appointed counsel, and was also represented by counsel in state-court proceedings concerning his imprisonment.
Court’s analysis
The court addressed Bonilla’s ability to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without fees may do so only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show imminent danger. Therefore, he could not proceed without paying the filing fees.
The court further stated that, even if an application to proceed without fees 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, and Mullis v. U.S. Bankruptcy Court. The opinion does not separately explain in detail how each cited rule applied to each individual case.
The court also rejected any suggestion that the judge’s impartiality could reasonably be questioned merely because Bonilla had filed repetitive and frivolous cases. The opinion noted that Bonilla named the judge as a defendant in four of the cases but made no specific allegations against her.
Disposition
Judge Phyllis J. Hamilton 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 additional documents Bonilla submitted in the closed cases.
The opinion states that the cases were dismissed with prejudice, but it does not provide a separate claim-by-claim disposition for each complaint.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.