Bonilla v. San Francisco County Superior Court
- Phyllis Hamilton
- 4:25-cv-06895
- U.S. District Court · Northern District of California
- 4
Bonilla v. Alameda County Superior Court: Judge Hamilton dismissed the multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and other legal barriers applied.
Steven Wayne Bonilla’s multiple civil-rights lawsuits were dismissed with prejudice. The order also affects any further documents he attempts to submit in those closed cases because the clerk was directed to return them without filing.
What happened
In Steven Wayne Bonilla v. Alameda County Superior Court et al., Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights lawsuits against federal judges, state judges, and state courts. The lawsuits challenged his conviction and how other state and federal cases were handled.
The court ruled that Bonilla could not proceed without paying the filing fees because he had previously been disqualified from proceeding without fees and his complaints did not show imminent danger of serious physical injury when filed. The court also stated that, even if he had been allowed to proceed without fees, the lawsuits would be barred by other legal rules. It dismissed the cases with prejudice, terminated pending motions, and ordered the clerk to close the cases.
Judge Phyllis J. Hamilton also rejected the suggestion that her impartiality could reasonably be questioned because of Bonilla’s repetitive filings. The order states that the clerk must return any further documents Bonilla submits in the closed cases without filing them.
The detailed version
- Bonilla v. San Francisco County Superior Court · No. 4:25-cv-06895
- Phyllis Hamilton
- Aug. 20, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical complaints without a lawyer under 42 U.S.C. § 1983, a federal law that allows claims against certain state actors for violations of federal rights. The caption lists numerous case numbers, including 25-cv-6189-PJH. The defendants included various federal judges, state judges, and state courts. Bonilla sought relief concerning his underlying conviction and the handling of his other cases in state and federal court.
The order states that Bonilla had a pending federal petition challenging his custody in the same court, with appointed counsel, and was also represented by counsel in state-court proceedings. It further states that he had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed the complaint.
Rulings
The court determined that the allegations did not show imminent danger at the time of filing. Bonilla therefore could not proceed without paying the filing fees. The court also stated that, even if an application to proceed without paying fees had been granted, the lawsuits would 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 does not separately explain which rule applied to which individual case or claim.
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submits in the closed cases.
Recusal issue
The court also addressed whether Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. It concluded that these were not cases requiring her to step aside. The order notes that Bonilla named Judge Hamilton as a defendant in four of the cases but made no specific allegations against her.
Disposition
The multiple cases were dismissed with prejudice, pending motions were terminated, and the cases were closed. The opinion states that the court’s order was entered by Judge Phyllis J. Hamilton on August 20, 2025.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.