Bonilla v. Blum
- Phyllis Hamilton
- 4:25-cv-06664
- 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 because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk to return future submissions without filing them.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical 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 did not show he faced imminent danger of serious physical injury when he filed the complaints. Because he had previously been barred from proceeding without paying the filing fee, he could not proceed without payment. The court also said that, even if he had qualified to proceed without payment, several legal doctrines would bar the lawsuits.
In Bonilla v. Alameda County Superior Court et al., Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return future filings without filing them.
The detailed version
- Bonilla v. Blum · No. 4:25-cv-06664
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned 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 his other cases had been handled.
The court noted that Bonilla had a pending federal petition challenging his conviction in the same court with appointed counsel. It also noted that he was represented by counsel in state-court proceedings concerning that petition.
Proceeding Without Paying the Filing Fee
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 proceeding without payment may do so 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 imminent danger at the time of filing. It therefore concluded that he could not proceed without paying the filing fee.
Other Bars to the Lawsuits
The court further stated that, even if an application to proceed without paying the filing fee had been granted, the lawsuits would be barred under the legal 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 provide a separate claim-by-claim explanation of how each cited rule applied to each case.
Recusal Discussion
The court rejected the suggestion that the presiding judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and frivolous filings. The court stated that a judge generally has a duty to decide cases assigned to that judge unless legitimate grounds for recusal exist. A footnote stated that Bonilla named the judge as a defendant in four of the cases but made no specific allegations against the judge.
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.