Bonilla v. Anderhold
- Phyllis Hamilton
- 4:25-cv-06585
- U.S. District Court · Northern District of California
- 4
In Bonilla v. Alameda County Superior Court, Judge Hamilton dismissed the cases with prejudice after finding no imminent danger and several legal bars.
Steven Wayne Bonilla’s multiple civil-rights lawsuits were dismissed with prejudice; the order also affects the defendants named in those cases and prevents further filings in the closed cases from being filed.
What happened
In Bonilla v. Alameda County Superior Court et al., Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed many nearly identical civil-rights lawsuits against federal judges, state judges, and state courts. He sought relief related to his conviction and the handling of his other cases.
The court said Bonilla could not waive the filing fee because he had previously been disqualified from doing so unless he showed that he faced an immediate risk of serious physical injury. The court found that his complaints did not show such a risk. It also said that, even if he could waive the fee, the lawsuits were barred by several legal rules.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and ordered the clerk to close the cases and return future filings in them without filing them. The opinion also rejected recusal based on the repetitive and frivolous filings.
The detailed version
- Bonilla v. Anderhold · No. 4:25-cv-06585
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints were described as nearly identical. They named various federal judges, state judges, and state courts as defendants and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases by state and federal courts.
The opinion states that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel and was also represented by counsel in state-court proceedings concerning such a petition.
Filing-fee status and legal bars
The court addressed Bonilla’s request, to the extent he sought to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), the court said he was disqualified from proceeding without the fee unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show imminent danger, so Bonilla could not proceed without paying the filing fee.
The court further stated that, even if a fee-waiver application were granted, the lawsuits would be barred under the rules discussed 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 explain how each cited rule applied to each individual case.
Recusal
The court also considered the fact that Bonilla named the judge who issued the order as a defendant in four of the cases. It concluded that the repetitive and allegedly frivolous nature of the filings did not provide a reasonable basis to question the judge’s impartiality. The court said that, absent legitimate grounds for recusal, a judge has a duty to decide assigned cases.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases. The order states that the judge had issued numerous prior orders concerning Bonilla’s other cases and that Bonilla had an extensive history of filing similar cases.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.