Bonilla v. Benson
- Phyllis Hamilton
- 4:25-cv-06346
- 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 other legal bars.
Steven Wayne Bonilla and the multiple cases covered by the order; the named federal and state judicial defendants were affected by the closure of those cases.
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 cases under federal law. He named federal judges, state judges, and state courts and sought relief related to his conviction or the handling of his other cases.
The court found that Bonilla could not proceed without paying the filing fees because his allegations did not show that he faced imminent danger of serious physical injury when he filed. The court also said that, even if he were allowed to proceed without paying, the lawsuits would be barred by several legal rules. It dismissed the cases with prejudice, terminated all pending motions, and closed the cases.
Judge Phyllis J. Hamilton also rejected any suggestion that her impartiality could reasonably be questioned because of the repetitive filings. She directed the clerk to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Benson · No. 4:25-cv-06346
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints presented nearly identical claims against various federal judges, state judges, and state courts. Bonilla sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts.
The opinion notes that Bonilla has a pending federal petition challenging his custody in the same court, where he has appointed counsel, and that he is represented by counsel in state-court proceedings concerning his custody.
Filing-Fee Status and Legal Bars
The court stated that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed the 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 the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion does not analyze each rule separately in connection with each case.
Ruling
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in those closed cases.
Impartiality
The court rejected the argument that the judge’s impartiality might reasonably be questioned because of the repetitive and allegedly frivolous nature of the filings. The opinion notes that Bonilla named the judge as a defendant in four of the cases but presented no specific allegations against her.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.