Bonilla v. Li Colsi
- Phyllis Hamilton
- 4:25-cv-06350
- 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 numerous related cases he filed; the order also concerned the federal judges, state judges, and state courts named as defendants.
What happened
In Steven Wayne Bonilla v. Alameda County Superior Court et al., a state prisoner filed many similar civil-rights cases without a lawyer. He sued federal judges, state judges, and state courts over his conviction and how other cases were handled.
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 the lawsuits would be barred by several legal rules even if he could proceed without paying.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The court also said it would return future filings in the closed cases without filing them and declined to recuse itself.
The detailed version
- Bonilla v. Li Colsi · No. 4:25-cv-06350
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and condemned prisoner, filed numerous nearly identical complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute for claims against government actors. The cases named various federal judges, state judges, and state courts as defendants. The complaints sought relief concerning Bonilla’s underlying conviction and the handling of his other cases.
The order states that Bonilla had a pending federal petition challenging his imprisonment in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings concerning his imprisonment.
Filing-fee restriction
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute allows a disqualified prisoner to proceed without paying only if the complaint shows that the prisoner was in imminent danger of serious physical injury when the complaint was filed.
The court found that the allegations did not show imminent danger at the relevant time. It therefore ruled that Bonilla 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 legal rules identified in the order, including rules concerning challenges to criminal convictions, interference with ongoing state proceedings, challenges to federal-court actions, and challenges involving judicial immunity or related limits. The order cited Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.
Ruling
The court dismissed the cases with prejudice. The order also directed the clerk to terminate all pending motions and close the cases. It directed the clerk to return, without filing, any further documents Bonilla submitted in those closed cases.
The court separately considered whether the judge’s impartiality might reasonably be questioned because of the repetitive and allegedly frivolous filings. It concluded that these were not cases requiring the judge’s recusal. The order noted that Bonilla named the judge 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.