Bonilla v. Battaglia
- Phyllis Hamilton
- 4:25-cv-06663
- U.S. District Court · Northern District of California
- 4
In Bonilla v. Alameda County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and other legal bars.
Steven Wayne Bonilla, the plaintiff and a state prisoner, and the defendants named in his multiple civil-rights cases, including federal judges, state judges, and state courts.
What happened
In Steven Wayne Bonilla v. Alameda County Superior Court et al., Bonilla, a state prisoner, filed many nearly identical civil-rights complaints without a lawyer. He sued federal and 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 prior filings disqualified him from that status and his complaints did not show imminent danger of serious physical injury. 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, directed the clerk to terminate pending motions and close the cases, and ordered that later documents submitted in those closed cases be returned without filing. The court also concluded that the repetitive filings did not require Judge Hamilton’s recusal.
The detailed version
- Bonilla v. Battaglia · No. 4:25-cv-06663
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, described by the court as a state prisoner under a death sentence, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. 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 his other cases had been handled.
The court noted that Bonilla had a pending federal petition challenging his imprisonment in the same court, with appointed counsel, and that he was also represented by counsel in state-court proceedings concerning his imprisonment.
Filing-fee status and legal bars
The court addressed Bonilla’s possible applications to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally cannot proceed without paying unless 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. It therefore held that he could not proceed without paying the filing fee.
The court further stated that, even if an application to proceed without paying 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 opinion does not provide a separate claim-by-claim explanation of which rule applied to which complaint.
Ruling
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 court also rejected the suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. The opinion states that Bonilla named Judge Hamilton as a defendant in four of the cases but made no specific allegations against her. Judge Hamilton concluded that the filings did not provide a reason for recusal.
Disposition
Multiple cases: dismissed with prejudice. Pending motions: terminated. Cases: closed. Further documents in the closed cases: to be returned without filing.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.