Bonilla v. Place
- Phyllis Hamilton
- 4:25-cv-06576
- U.S. District Court · Northern District of California
- 4
In Bonilla v. Alameda County Superior Court, Judge Hamilton dismissed multiple cases with prejudice after finding no imminent danger and identifying legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also ended pending motions, closed the cases, and directed the clerk not to file further documents submitted in them.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against federal judges, state judges, and state courts. He sought relief related to his conviction and the handling of other cases.
The court found that Bonilla could not proceed without paying the filing fee because his allegations did not show imminent danger of serious physical injury. The court also said the lawsuits would be barred by several legal rules even if he could proceed without paying.
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 them without filing them.
The detailed version
- Bonilla v. Place · No. 4:25-cv-06576
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and condemned prisoner, filed numerous nearly identical complaints under 42 U.S.C. § 1983, the federal civil-rights statute for certain claims against state actors. He represented himself in these cases. The defendants included various federal judges, state judges, and state courts. The complaints sought relief concerning Bonilla’s underlying conviction and the way his other state and federal cases had been handled.
The opinion states that Bonilla had a pending federal petition challenging his imprisonment in the same court, with appointed counsel, and was represented by counsel in state-court proceedings. The court also noted his history of filing similar cases.
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 from that filing-fee waiver may proceed without payment only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger, so he could not proceed without paying the filing fee.
The court further held that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate, claim-by-claim analysis of those barriers.
The court also rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. The opinion noted that Bonilla named Judge Hamilton as a defendant in four of the cases but made no specific allegations against her.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in these closed cases.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.