Bonilla v. Pennypacker
- Phyllis Hamilton
- 4:25-cv-06850
- 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 barriers.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice; the defendants named in those cases were not required to litigate the claims.
What happened
In Bonilla v. Alameda County Superior Court, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights cases against various federal judges, state judges, and state courts. He sought relief related to his conviction and the handling of his other cases.
The court found 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 complaints. The court also stated that, even if he could proceed without paying, the lawsuits would be barred by several legal doctrines, including rules concerning challenges to criminal convictions and interference with ongoing proceedings. The court dismissed the cases with prejudice.
Judge Phyllis J. Hamilton also declined to recuse herself, stating that the repetitive filings did not provide a legitimate reason to question her impartiality. The clerk was ordered to terminate all pending motions, close the cases, and return future documents submitted in them without filing them.
The detailed version
- Bonilla v. Pennypacker · No. 4:25-cv-06850
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a law allowing civil-rights claims against state actors. The complaints presented nearly identical claims and named various federal judges, state judges, and state courts as defendants. Bonilla sought relief concerning his underlying conviction and the handling of other cases in state and federal courts.
The opinion states that Bonilla was a condemned prisoner with a pending federal habeas petition in the same court for which he had appointed counsel. It also states that he was represented by counsel in state-court habeas proceedings.
Proceeding Without Paying Filing Fees
The court stated that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he showed that he faced imminent danger of serious physical injury when he filed the complaint. The court found that the allegations in these complaints did not show imminent danger at the time of filing. Bonilla therefore could not proceed without paying the filing fees.
Other Grounds for Dismissal
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion described these doctrines as barriers to the lawsuits but did not provide a separate detailed analysis of each one.
Ruling
The court dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in the closed cases.
Recusal
The court rejected the suggestion that the undersigned judge's impartiality might reasonably be questioned because of the repetitive and frivolous nature of the filings. The court stated that there were no legitimate reasons for recusal. It also noted that Bonilla named the judge as a defendant in four of the cases but made no specific allegations against her.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.