Bonilla v. Beracivengo
- Phyllis Hamilton
- 4:25-cv-06303
- U.S. District Court · Northern District of California
- 4
In Bonilla v. Alameda County Superior Court, Judge Hamilton dismissed multiple federal civil-rights cases with prejudice after finding no imminent-danger exception and citing additional legal bars.
Steven Wayne Bonilla and the multiple cases he filed; the cases named various federal judges, state judges, and state courts as defendants.
What happened
In Steven Wayne Bonilla v. Alameda County Superior Court et. al., the plaintiff, a condemned state prisoner representing himself, filed many similar civil-rights cases under federal law. He sued various federal judges, state judges, and state courts over his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fees because he had previously been barred from that status unless he was in immediate danger of serious physical injury. The court found that his complaints did not show such danger. It also said that, even if he were allowed to proceed without paying, several legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and ordered the clerk to close the cases and return further filings without filing them.
The detailed version
- Bonilla v. Beracivengo · No. 4:25-cv-06303
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple similar complaints without a lawyer. The complaints asserted civil-rights claims under 42 U.S.C. § 1983 and named various federal judges, state judges, and state courts as defendants. The opinion says the complaints sought relief concerning Bonilla’s underlying conviction or the handling of his other cases.
The opinion also notes that Bonilla had a pending federal petition concerning his imprisonment, with appointed counsel, and was represented by counsel in state-court proceedings.
Filing-fee status
The court said Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute permits an otherwise disqualified prisoner to proceed without paying only when the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed.
The court found that the allegations did not show imminent danger. It therefore concluded that Bonilla could not proceed without paying the filing fee.
Other legal barriers
The court added that, even if Bonilla had been allowed to proceed without paying the fee, the lawsuits would be barred under the rules or doctrines 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 provide a separate analysis of each doctrine in this order.
The court also rejected the suggestion that the judge’s impartiality could reasonably be questioned merely because of the repetitive and frivolous nature of the filings. The opinion states that Bonilla named the judge as a defendant in four of the cases but made no specific allegations against her.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. The order was signed by United States District Judge Phyllis J. Hamilton.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.