Bonilla v. Thompson
- Phyllis Hamilton
- 4:25-cv-06353
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Thompson, Judge Hamilton dismissed multiple civil-rights cases with prejudice because IFP restrictions and other legal bars prevented them from proceeding.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The named federal judges, state judges, and state courts were defendants in those cases.
What happened
In Bonilla v. Thompson, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits under a federal law allowing claims against state officials. He named federal judges, state judges, and state courts as defendants and sought relief related to his conviction and the handling of other cases.
The court ruled that Bonilla could not proceed without paying filing fees because his allegations did not show imminent danger of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without paying, the lawsuits were barred by other legal rules. It dismissed the cases with prejudice, terminated all pending motions, and closed the cases.
Judge Phyllis J. Hamilton also concluded that her impartiality could not reasonably be questioned based on the repetitive filings, including cases in which Bonilla named her as a defendant without specific allegations.
The detailed version
- Bonilla v. Thompson · No. 4:25-cv-06353
- Phyllis Hamilton
- Aug. 26, 2025
Background
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints 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 way his other state and federal cases had been handled.
The order states that Bonilla is a condemned prisoner with a pending federal petition challenging his custody in the same court, where he has appointed counsel. It also states that he is represented by counsel in state-court proceedings concerning that petition.
Proceeding Without Paying Filing Fees
The court explained that Bonilla had previously been disqualified from proceeding in forma pauperis, meaning without paying the required filing fees, under 28 U.S.C. § 1915(g). He could proceed without paying only if he showed that he faced imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger.
Other Bars and Disposition
The court further stated that, even if Bonilla’s applications to proceed without paying fees were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The court therefore dismissed the cases with prejudice. The order also directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
Impartiality
The court rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. The order noted that Bonilla named Judge Hamilton as a defendant in three of the cases but made no specific allegations against her. Judge Hamilton concluded that there was no legitimate reason for her to recuse herself.
Result
All listed cases were dismissed with prejudice, pending motions were terminated, and the cases were closed.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.