Bonilla v. Lake County Superior Court
- Phyllis Hamilton
- 4:25-cv-06855
- 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 filing fees and his claims faced legal barriers.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the order also terminated pending motions, closed the cases, and directed the clerk to return future filings in those closed cases without filing them.
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 sued federal judges, state judges, and state courts over his conviction and the handling of his other cases.
The court said Bonilla had previously been barred from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury. The complaints did not show that danger. The court also said that, even if he had been allowed to proceed without paying fees, legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return future filings in those closed cases without filing them.
The detailed version
- Bonilla v. Lake County Superior Court · No. 4:25-cv-06855
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints were nearly identical. They named various federal judges, state judges, and state courts as defendants and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases.
The opinion also states that Bonilla had a pending federal petition challenging his detention in the same court, with appointed counsel, and was represented by counsel in state-court proceedings. The opinion refers to those matters by case number and does not describe their ultimate outcomes.
Proceeding without filing fees
The court explained that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute permits a disqualified prisoner to proceed without the fee only if the complaint shows that the prisoner was in immediate danger of serious physical injury when the complaint was filed. The court found that these complaints did not show such danger.
Other legal barriers
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under legal rules 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 separately analyze each rule’s application to each individual case.
Ruling
The court dismissed the cases with prejudice. It also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. 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. Judge Phyllis J. Hamilton signed the order.
Scope of the order
The opinion lists numerous related case numbers. The supplied case name refers to “Lake County Superior Court,” but the opinion’s caption names “Alameda County Superior Court et al.” This summary follows the opinion’s caption.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.