Bonilla v. Williams
- Phyllis Hamilton
- 4:25-cv-06853
- 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 claims faced legal bars.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. The clerk was directed to close the cases, terminate pending motions, and return later submissions without filing them.
What happened
Bonilla v. Alameda County Superior Court involved multiple nearly identical complaints filed by Steven Wayne Bonilla, a state prisoner representing himself. The complaints were brought under a federal civil-rights law and named various federal judges, state judges, and state courts as defendants.
Bonilla sought relief concerning his conviction and the handling of other cases in state and federal court. The court found that he could not proceed without prepaying fees because his allegations did not show that he faced an immediate risk of serious physical injury when he filed the complaints. The court also said the lawsuits would be barred by other legal rules even if fee-free filing had been allowed.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was ordered to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Williams · No. 4:25-cv-06853
- 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 federal law that permits certain 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 way his other cases had been handled by state and federal courts.
The opinion states that Bonilla also had a pending federal petition challenging his imprisonment, with appointed counsel, and was represented by counsel in state-court proceedings concerning his imprisonment. The court also noted Bonilla's extensive history of filing similar cases.
Court's analysis
The court addressed Bonilla's potential request to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally may not proceed without paying unless the complaint shows that the prisoner faced an immediate danger of serious physical injury when it was filed. The court determined that Bonilla's allegations did not show such danger. It therefore concluded that he could not proceed without paying the filing fee.
The court further stated that, even if permission to proceed without paying had been granted, the lawsuits would still be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not decide the underlying civil-rights claims on their merits.
The court also rejected any suggestion that the judge's impartiality could reasonably be questioned because of Bonilla's repetitive and allegedly frivolous filings. The opinion noted that Bonilla named the judge as a defendant in four of the cases but made no specific allegations against her.
Disposition
The court dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases, and 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.