Bonilla v. Hamilton
- Phyllis Hamilton
- 4:25-cv-06763
- 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 the suits were barred.
Steven Wayne Bonilla, whose multiple lawsuits were dismissed with prejudice, and the named federal judges, state judges, and state courts who were defendants.
What happened
In Bonilla v. Alameda County Superior Court, Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights lawsuits without a lawyer. He named federal judges, state judges, and state courts as defendants and sought relief concerning his conviction and the handling of his other cases.
The court said Bonilla was barred from proceeding without paying the filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed. The court found that his complaints did not make that showing. It also said that, even if he had been allowed to proceed without paying, several legal rules barred the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate pending motions and close the cases, and directed the clerk to return future documents Bonilla submitted in those closed cases without filing them. Judge Hamilton also concluded that the repetitive filings did not require her recusal.
The detailed version
- Bonilla v. Hamilton · No. 4:25-cv-06763
- 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. “Pro se” means that he filed without a lawyer. The complaints were nearly identical. They named various federal judges, state judges, and state courts as defendants and sought relief related to Bonilla’s underlying conviction or the handling of his other cases.
The opinion states that Bonilla is a condemned prisoner with a pending federal petition challenging his custody in the same district, where he has appointed counsel. It also states that he is represented by counsel in state-court proceedings concerning his custody.
Court’s analysis
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 that status may proceed without paying only if he was facing imminent danger of serious physical injury when he filed the complaint. The court stated that Bonilla had previously been disqualified under that provision and concluded that the allegations in these complaints did not show imminent danger at the time of filing.
The court further stated that, even if an application to proceed without paying had been granted, the lawsuits would be barred under the rules or doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not provide a separate, claim-by-claim explanation of how each cited doctrine applied to each complaint.
The court also considered whether the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and allegedly frivolous filings. It concluded that these cases did not require the judge to recuse herself. The opinion notes that Bonilla named Judge Hamilton as a defendant in four of the cases but made no specific allegations against her in those cases.
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. The order was signed by United States District Judge Phyllis J. Hamilton.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.