Bonilla v. Reeves
- Phyllis Hamilton
- 4:25-cv-06438
- U.S. District Court · Northern District of California
- 4
In Bonilla v. Alameda County Superior Court, Judge Hamilton dismissed the related civil-rights cases with prejudice because Bonilla could not proceed without filing fees and his claims were barred.
Steven Wayne Bonilla’s related civil-rights cases were dismissed with prejudice. The defendants named in those cases were affected by the closures, and pending motions were terminated. The clerk was directed to return, without filing, further documents Bonilla submits in the closed cases.
What happened
In Steven Wayne Bonilla v. Alameda County Superior Court et al., Bonilla, a state prisoner representing himself, filed many nearly identical civil-rights cases against federal judges, state judges, and state courts. He sought relief concerning his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying the filing fee because he had been barred from using the fee-waiver process and had not shown an immediate danger of serious physical injury when he filed. The court also said that, even if it had allowed the fee waiver, the lawsuits would be barred under several cited legal doctrines. It dismissed the cases with prejudice, terminated 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. The clerk was directed to return, without filing, any further documents Bonilla submits in these closed cases.
The detailed version
- Bonilla v. Reeves · No. 4:25-cv-06438
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints were filed in the many related case numbers listed in the caption. Bonilla named various federal judges, state judges, and state courts as defendants. The court said the complaints were nearly identical and sought relief concerning Bonilla’s underlying conviction or the way his other cases had been handled.
The opinion states that Bonilla is a condemned prisoner with a pending federal petition challenging his custody in this court, where he has appointed counsel. It also states that he is represented by counsel in state-court proceedings concerning his petition. The opinion further notes Bonilla’s extensive history of filing similar cases.
Filing-fee restriction
To the extent Bonilla sought permission to proceed without paying the filing fee, the court held that 28 U.S.C. § 1915(g) disqualified him from doing so unless he showed that he faced an imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger. Bonilla therefore could not proceed under the fee-waiver procedure.
Other grounds for dismissal
The court stated that, even if a fee-waiver application had been granted, the lawsuits would be barred under the principles identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each doctrine’s application to each complaint. It concluded that the cases were dismissed with prejudice.
Recusal and case disposition
The court also determined that these cases did not provide a basis to question the undersigned judge’s impartiality because of the repetitive and allegedly frivolous filings. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submits in the closed cases.
The order dismissed the cases with prejudice. It did not grant Bonilla permission to proceed without paying the filing fee, and it terminated the pending motions and the cases.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.