Bonilla v. Woriyo
- Phyllis Hamilton
- 4:25-cv-06344
- 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 because Bonilla did not qualify for fee-free filing and the claims faced legal bars.
Steven Wayne Bonilla and the defendants in the related civil-rights cases, including various federal judges, state judges, and state courts.
What happened
In Bonilla v. Alameda County Superior Court and related cases, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed nearly identical civil-rights complaints against various federal judges, state judges, and state courts. He challenged his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fee because he had previously been barred from that status and did not show that he faced an immediate serious physical danger when he filed. The court also said that, even if he qualified, the lawsuits would be barred by several legal rules. It dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return any further filings in them without filing them.
Judge Phyllis J. Hamilton also rejected the suggestion that her impartiality could reasonably be questioned because of Bonilla’s repetitive filings. The court said there was no legitimate reason for her to step aside.
The detailed version
- Bonilla v. Woriyo · No. 4:25-cv-06344
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple nearly identical civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The defendants included various federal judges, state judges, and state courts. The complaints sought relief concerning Bonilla’s underlying conviction and the way his other state and federal cases had been handled.
The order states that Bonilla had a pending federal petition challenging his custody, in which he had appointed counsel, and that he was represented by counsel in state-court proceedings challenging his custody. The order also states that Bonilla had an extensive history of filing similar cases.
Fee status and legal bars
To the extent Bonilla sought permission to proceed without paying the filing fee, the court held that he was disqualified under 28 U.S.C. § 1915(g) because of prior qualifying filings. That statute permits a disqualified prisoner to proceed without the fee only if he shows that he was facing an immediate danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger.
The court further held that, even if a fee-waiver application were granted, the lawsuits would be barred under several doctrines and precedents, including rules concerning challenges to criminal convictions, interference with ongoing state proceedings, certain challenges to federal court actions, and judicial immunity. The order did not separately analyze the merits of the individual claims.
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 additional documents Bonilla submitted in the closed cases.
Recusal issue
The court also addressed whether its judge’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous nature of the filings. Judge Hamilton concluded that these circumstances did not require recusal. The order states that a judge has a duty to sit in assigned cases unless legitimate grounds for recusal exist. A footnote states that Bonilla named Judge Hamilton as a defendant in four of the cases but made no specific allegations against her.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.