Bonilla v. Buckley
- Phyllis Hamilton
- 4:25-cv-06439
- U.S. District Court · Northern District of California
- 4
Bonilla v. Alameda County Superior Court: Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because Bonilla could not proceed without filing fees and his claims faced legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk to return further submissions in those cases without filing them.
What happened
In Bonilla v. Alameda County Superior Court et al., Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights cases without a lawyer. He sued various federal judges, state judges, and state courts over his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying filing fees because his prior filings disqualified him from that status, and his complaints did not show an immediate danger of serious physical injury when filed. The court also said that, even if he could proceed without fees, several legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was ordered to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Buckley · No. 4:25-cv-06439
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple similar civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. He is a condemned prisoner with a pending federal petition challenging his custody in this court, where he has appointed counsel. The opinion also states that he is represented by counsel in state-court proceedings concerning a similar petition.
Bonilla named various federal judges, state judges, and state courts as defendants. The opinion says that his claims concerned his underlying conviction or the way his other cases had been handled by state and federal courts.
Court’s analysis
The court addressed Bonilla’s ability to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified based on prior qualifying filings may proceed without paying only if the complaint shows that the prisoner faced an immediate danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show that danger. It therefore held that he could not proceed without paying the filing fee.
The court added that, even if an application to proceed without paying the filing fee were granted, the lawsuits would still be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not separately explain how each rule applied to each case.
The court also rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of Bonilla’s 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.
Disposition
Judge Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases. The opinion also states that Bonilla had an extensive history of filing similar cases, but it does not identify separate dispositions for individual claims or defendants.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.