Bonilla v. Day
- Phyllis Hamilton
- 4:25-cv-06579
- U.S. District Court · Northern District of California
- 4
In Bonilla v. Alameda County Superior Court et al., Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying filing fees and his claims were barred.
Steven Wayne Bonilla’s multiple pro se civil-rights cases were dismissed with prejudice, affecting the defendants named in those cases and requiring the clerk to close the cases and return later submissions without filing.
What happened
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights cases against various federal judges, state judges, and state courts. He sought relief related to his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying filing fees because he did not show that he faced an immediate danger of serious physical injury when he filed the complaints. The court also said that, even if Bonilla had been allowed to proceed without paying fees, the lawsuits would be barred under several legal doctrines and cases, including rules concerning challenges to convictions and interference with ongoing proceedings.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that further documents submitted in the closed cases be returned without filing.
The detailed version
- Bonilla v. Day · No. 4:25-cv-06579
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple pro se civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical. They named various federal judges, state judges, and state courts as defendants and sought relief concerning Bonilla’s underlying conviction or the way other cases had been handled by state and federal courts.
The order also states that Bonilla is a condemned prisoner with a pending federal habeas petition in the district court, represented by appointed counsel, and that he is represented by counsel in state habeas proceedings.
Filing-Fee Determination
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding in forma pauperis, meaning without paying the required filing fees, unless he showed that he was under imminent danger of serious physical injury when he filed each complaint. The court found that the allegations did not show such danger. Bonilla therefore could not proceed in forma pauperis.
Other Bars to the Lawsuits
The court further stated that, even if an application to proceed in forma pauperis had been 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 separately analyze the claims under each cited authority.
The court also stated that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the undersigned judge’s impartiality. A footnote stated 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 ordered the clerk to return, without filing, any further 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.