Bonilla v. Elvine-Kreis
- Phyllis Hamilton
- 4:25-cv-06436
- U.S. District Court · Northern District of California
- 4
Bonilla v. Alameda County Superior Court: Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and applying legal bars.
Steven Wayne Bonilla and the defendants named in the multiple related lawsuits, including various federal judges, state judges, and state courts.
What happened
In Steven Wayne Bonilla v. Alameda County Superior Court et al., Steven Wayne Bonilla, a state prisoner, filed many similar civil-rights lawsuits without a lawyer. He named federal judges, state judges, and state courts and sought relief related to his conviction or the handling of other cases.
Bonilla sought to proceed without paying filing fees in these cases. The court said he was barred from doing so because he had previously been disqualified from that status, and his complaints did not show that he faced an immediate danger of serious physical injury when he filed them.
The court also said that, even if Bonilla could proceed without paying fees, the lawsuits were barred by several legal doctrines. Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, closed the cases, and ordered the clerk to return future submissions without filing them.
The detailed version
- Bonilla v. Elvine-Kreis · No. 4:25-cv-06436
- 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, the federal law that allows certain civil-rights claims against state actors. The order covers numerous related case numbers. Bonilla named various federal judges, state judges, and state courts as defendants. The order says he sought relief concerning his underlying conviction and the handling of his other state and federal cases.
The order also notes that Bonilla is a condemned prisoner with a pending federal petition challenging his custody in the same district, where he has appointed counsel. It further states that he is represented by counsel in state-court proceedings.
Filing-fee status
To the extent Bonilla sought permission to proceed without paying filing fees, the court applied 28 U.S.C. § 1915(g). That provision disqualifies a prisoner from proceeding without paying the fee after certain prior cases, unless 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. It therefore held that Bonilla could not proceed without paying the filing fee.
Other barriers and disposition
The court added that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order did not decide the underlying civil-rights claims. It dismissed the cases with prejudice.
The court also rejected any suggestion that the assigned judge's impartiality could reasonably be questioned merely because Bonilla had filed repetitive and frivolous cases. The order notes that Bonilla named the assigned judge as a defendant in four of the 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 ordered to return, without filing, any further documents Bonilla submits in the closed cases.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.