Bonilla v. Hamilton
- Phyllis Hamilton
- 4:25-cv-06281
- U.S. District Court · Northern District of California
- 4
In Bonilla v. Alameda County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and identifying procedural bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also affected the various federal judges, state judges, and state courts named as defendants by ending these cases and directing the clerk to return later submissions without filing.
What happened
In Bonilla v. Alameda County Superior Court, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights complaints against various federal judges, state judges, and state courts. The complaints sought relief concerning his conviction and the handling of his other cases.
The court said Bonilla was barred from proceeding without paying the filing fee unless he showed that he faced an immediate danger of serious physical injury when he filed. The court found that his allegations did not make that showing. It also said that, even if he were allowed to proceed without paying, the lawsuits would be barred by several legal doctrines concerning challenges to convictions, ongoing state proceedings, and federal judicial decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that further documents submitted in the closed cases be returned without filing. The court also rejected any suggestion that the judge’s impartiality could reasonably be questioned based on the repetitive and frivolous filings.
The detailed version
- Bonilla v. Hamilton · No. 4:25-cv-06281
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, identified in the order as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The order lists numerous related case numbers. The complaints were nearly identical and named various federal judges, state judges, and state courts as defendants. Bonilla sought relief concerning his underlying conviction and the way his other cases had been handled by state and federal courts.
The order also states that Bonilla had a pending federal petition challenging his detention in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings concerning such a petition. The court referred to Bonilla’s history of filing similar cases.
Filing-fee status and legal bars
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he showed that he was in immediate danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger.
The court further stated that, even if an application to proceed without paying the filing fee 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 opinion did not separately analyze which specific doctrine applied to each case or claim.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.
The court separately addressed its own impartiality. It concluded that these were not cases in which the undersigned judge’s impartiality might reasonably be questioned because of the repetitive and frivolous filings. The order noted that Bonilla named Judge Hamilton as a defendant in four of the cases but made no specific allegations against her. Judge Phyllis J. 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.