Bonilla v.Gallagher
- Phyllis Hamilton
- 4:25-cv-06845
- U.S. District Court · Northern District of California
- 4
In Steven Wayne Bonilla v. Alameda County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying filing fees and the claims were barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. The order also affected the various federal judges, state judges, and state courts he named as defendants by closing the cases and terminating the pending motions.
What happened
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights cases under a federal law that allows claims against government officials. He named various federal judges, state judges, and state courts, and sought relief concerning his conviction and the handling of his other cases.
The court found that Bonilla could not proceed without paying the filing fee because he had been disqualified from that procedure unless he showed that he faced an immediate danger of serious physical injury. The court found no such danger in the complaints. It also said that, even if he were allowed to proceed without paying, the lawsuits would be barred by several legal doctrines concerning challenges to convictions, ongoing state proceedings, and actions against federal courts and judges.
In an order dated August 20, 2025, Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and directed the clerk to close the cases and return future filings without filing them.
The detailed version
- Bonilla v.Gallagher · No. 4:25-cv-06845
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal civil-rights statute. The order covers the case listed above and numerous related cases identified by additional case numbers. The complaints presented nearly identical claims and named various federal judges, state judges, and state courts as defendants. Bonilla sought relief related to his underlying conviction or the way his other cases had been handled by state and federal courts.
The order states that Bonilla had a pending federal petition challenging his custody in this court with appointed counsel and was represented by counsel in state-court proceedings concerning his custody. The court also noted Bonilla's history of filing similar cases.
Ruling
The court addressed Bonilla's requests to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has incurred the relevant filing restrictions may proceed without paying only if he was in immediate danger of serious physical injury when he filed the complaint. The court found that Bonilla's allegations did not show such danger. It therefore ruled that he could not proceed without paying the filing fee.
The court further ruled that, even if an application to proceed without paying had been granted, the lawsuits would be barred under the legal doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate claim-by-claim analysis of those doctrines. It dismissed the cases with prejudice.
The court also rejected any suggestion that Judge Hamilton's impartiality could reasonably be questioned because of the repetitive and 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.
Disposition
Judge Phyllis J. Hamilton dismissed the cases 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.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.