Bonilla v. Kaufman
- Phyllis Hamilton
- 4:25-cv-06352
- U.S. District Court · Northern District of California
- 4
Bonilla v. Alameda County Superior Court: Judge Hamilton dismissed multiple civil-rights cases with prejudice because IFP was unavailable and the lawsuits faced legal bars.
Steven Wayne Bonilla and the defendants named in the multiple cases, including various federal judges, state judges, and state courts. The cases were dismissed with prejudice, closed, and subject to the clerk's order to return further filings without filing them.
What happened
In Bonilla v. Alameda County Superior Court et al., Steven Wayne Bonilla, a state prisoner, filed many similar civil-rights cases without a lawyer. He sued various federal judges, state judges, and state courts over his conviction and the handling of other cases.
The court ruled that Bonilla could not proceed without paying filing fees because his allegations did not show imminent danger of serious physical injury when he filed. The court also said that, even if he had been allowed to proceed without paying fees, the lawsuits would be barred by several legal rules. It dismissed the cases with prejudice.
Judge Phyllis J. Hamilton said her impartiality could not reasonably be questioned based on the repetitive filings, terminated all pending motions, closed the cases, and directed the clerk to return further filings in those closed cases without filing them.
The detailed version
- Bonilla v. Kaufman · No. 4:25-cv-06352
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple similar complaints without a lawyer under 42 U.S.C. § 1983, a statute that permits certain civil-rights lawsuits against government actors. The complaints named various federal judges, state judges, and state courts as defendants. Bonilla sought relief concerning his underlying conviction and the way his other state and federal cases had been handled.
The order covers numerous cases, including Case Nos. 25-cv-6189-PJH, 25-cv-6267-PJH, 25-cv-6269-PJH, 25-cv-6276-PJH, 25-cv-6277-PJH, 25-cv-6278-PJH, 25-cv-6280-PJH, 25-cv-6281-PJH, 25-cv-6300-PJH, 25-cv-6301-PJH, 25-cv-6302-PJH, 25-cv-6303-PJH, and additional related cases listed in the caption.
Ruling
The court held that Bonilla was disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger. Therefore, Bonilla could not proceed without paying the filing fee.
The court further ruled that, even if an application to proceed without paying fees 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, and Mullis v. U.S. Bankruptcy Court. The court therefore dismissed the cases with prejudice.
Recusal and Case Closure
The court rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. The order noted that Bonilla named Judge Hamilton as a defendant in four cases but made no specific allegations against her.
The clerk was ordered to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any additional documents Bonilla submitted in those closed cases.
Classification
This is a procedural order because the court dismissed the cases based on filing-fee eligibility and threshold legal bars rather than deciding the underlying civil-rights claims on their merits.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.