Bonilla v. Givens
- Phyllis Hamilton
- 4:25-cv-06761
- U.S. District Court · Northern District of California
- 4
In Bonilla v. Alameda County Superior Court, Judge Hamilton dismissed multiple pro se civil-rights cases with prejudice because they lacked imminent-danger allegations and were legally barred.
Steven Wayne Bonilla’s numerous civil-rights cases were dismissed with prejudice; the order also terminated pending motions and closed those cases.
What happened
In Bonilla v. Alameda County Superior Court et al., Steven Wayne Bonilla, a state prisoner representing himself, filed many nearly identical civil-rights lawsuits against federal judges, state judges, and state courts. He challenged his conviction and how other state and federal cases were handled.
The court ruled that Bonilla could not proceed without paying the filing fees because his allegations did not show that he faced imminent danger of serious physical injury when he filed. The court also said that, even if he could proceed without those fees, the lawsuits were barred by several legal rules concerning challenges to convictions, ongoing state proceedings, and federal-court decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Givens · No. 4:25-cv-06761
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed numerous nearly identical complaints without a lawyer under 42 U.S.C. § 1983, the federal law allowing certain civil-rights claims against state actors. The complaints named various federal judges, state judges, and state courts. They sought relief concerning Bonilla’s underlying conviction and the way his other state and federal cases had been handled.
The order identifies Bonilla as a condemned prisoner and notes that he had a pending federal petition challenging his detention with appointed counsel, as well as representation by counsel in state-court proceedings. The opinion also notes his history of filing similar cases.
Filing-fee determination
The court stated that Bonilla was disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing 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 at the relevant time. Therefore, Bonilla could not proceed without paying the filing fees.
Other grounds identified by the court
The court further stated that, even if an application to proceed without paying the filing fee were 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 provide a separate claim-by-claim explanation of which cited rule applied to which complaint.
The court also rejected any suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. The order noted that Bonilla named Judge Hamilton as a defendant in four of the cases but made no specific allegations against her in those cases.
Ruling and disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
The opinion does not decide the underlying validity of Bonilla’s conviction or otherwise resolve the merits of his civil-rights allegations. It disposes of the cases based on the filing-fee restriction and the legal bars identified by the court.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.