Bonilla v. Pulckamp
- Phyllis Hamilton
- 4:25-cv-06575
- U.S. District Court · Northern District of California
- 4
In Bonilla v. Alameda County Superior Court, Judge Hamilton dismissed multiple pro se civil-rights cases with prejudice after finding no imminent danger and applying filing bars.
Steven Wayne Bonilla’s multiple § 1983 lawsuits were dismissed with prejudice; the order also ended pending motions and closed the related cases.
What happened
In Bonilla v. Alameda County Superior Court et al., Steven Wayne Bonilla, a state prisoner, filed many nearly identical lawsuits without a lawyer. He sued federal judges, state judges, and state courts over his conviction and the handling of his other cases.
The court found that Bonilla could not proceed without paying the filing fee because his allegations did not show an immediate risk of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without paying, several legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return future filings in those cases without filing them.
The detailed version
- Bonilla v. Pulckamp · No. 4:25-cv-06575
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The opinion identifies him as a condemned prisoner and states that he has a pending federal petition challenging his detention or conviction with appointed counsel, as well as state court proceedings with counsel. The complaints were nearly identical and named various federal judges, state judges, and state courts as defendants. They sought relief concerning Bonilla’s underlying conviction and the way state and federal courts handled his other cases.
Proceeding Without Paying the Filing Fee
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee, 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 imminent danger. As a result, Bonilla could not proceed without paying the filing fee.
Other Bars to the Lawsuits
The court further held that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under several legal doctrines and precedents: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not provide a separate claim-by-claim analysis of these doctrines.
Recusal
The court also addressed the possibility that the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and allegedly frivolous filings. It concluded that these cases did not require the judge to step aside. The opinion notes that Bonilla named Judge Hamilton as a defendant in four of the cases but made no specific allegations against her in those cases.
Ruling and Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any additional documents Bonilla submitted in the closed cases.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.