Bonilla v. Shubb
- Phyllis Hamilton
- 4:25-cv-06348
- U.S. District Court · Northern District of California
- 4
In Bonilla v. Alameda County Superior Court, Judge Hamilton dismissed multiple civil-rights lawsuits with prejudice after finding no imminent danger and other legal bars.
Steven Wayne Bonilla’s multiple lawsuits were dismissed with prejudice, his pending motions were terminated, and the cases were closed. The defendants named in those lawsuits were no longer required to litigate them in those closed cases.
What happened
In Bonilla v. Alameda County Superior Court, Steven Wayne Bonilla, a state prisoner without a lawyer, filed multiple nearly identical civil-rights lawsuits. He named federal judges, state judges, and state courts as defendants and sought relief related to his conviction and the handling of his other cases.
The court found that Bonilla could not use the filing-fee waiver available to people who cannot afford court fees because his allegations did not show that he faced imminent danger of serious physical injury when he filed the lawsuits. The court also said that, even if he could proceed without paying fees, several legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return any further documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. Shubb · No. 4:25-cv-06348
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, described as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints were nearly identical. They named various federal judges, state judges, and state courts as defendants and sought relief concerning Bonilla’s underlying conviction or the way his other cases had been handled by state and federal courts.
The opinion also states that Bonilla had a pending federal petition challenging his detention with appointed counsel and was represented by counsel in state-court proceedings concerning his detention.
Filing-fee status
The court addressed whether Bonilla could proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may proceed without paying 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 at the relevant time. It therefore held that he could not proceed without paying the filing fee.
Other legal barriers
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under several legal doctrines and authorities, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each authority’s application to each complaint.
The court also rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. The opinion notes that Bonilla named Judge Hamilton as a defendant in four of the cases but made no specific allegations against her.
Ruling and case status
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any additional documents Bonilla submitted in those closed cases.
The court’s disposition was based on the filing-fee restriction and the stated legal bars rather than a determination that Bonilla’s underlying conviction-related claims were legally valid or invalid on their merits.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.