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N.D. Cal.Procedural orderFiled Aug. 26, 2025

Bonilla v. Judge Kaufman

Judge
Phyllis Hamilton
Docket
4:25-cv-06847
Court
U.S. District Court · Northern District of California
Pages
3
Civil RightsSection 1983Pro SeCivil Procedure
In one sentence

In Bonilla v. Thompson, Judge Hamilton dismissed the cases with prejudice because Bonilla could not proceed without fees and his lawsuits were barred.

Who this affects

Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice; the order also directed the clerk to close the cases and return future submissions without filing them.

What happened

In Bonilla v. Judge Jeffrey A. Thompson et al., Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed many similar civil-rights lawsuits against federal judges, state judges, and state courts. He sought relief concerning his conviction and the handling of his other cases.

The court said Bonilla was barred from proceeding without paying filing fees unless he showed an immediate danger of serious physical injury, which his complaints did not show. The court also said that, even if he could proceed without fees, the lawsuits were barred by several legal rules concerning challenges to convictions, ongoing state proceedings, and attempts to review other courts’ decisions.

Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return future filings in them without filing them.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Bonilla v. Judge Kaufman · No. 4:25-cv-06847
Judge
Phyllis Hamilton
Date
Aug. 26, 2025

Background

Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The order covers numerous cases with separate case numbers. Bonilla is described as a condemned prisoner who also has a pending federal habeas petition in the court with appointed counsel and is represented by counsel in state-court habeas proceedings.

The complaints presented nearly identical claims and named various federal judges, state judges, and state courts as defendants. The order says Bonilla sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts.

Court’s analysis

The court stated that Bonilla had 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 complaints. The court found that the allegations did not show such imminent danger.

The court further stated that, even if an application 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 opinion does not analyze each case separately or identify which cited bar applies to which complaint.

The order also addressed impartiality. It stated that the cases were not ones in which the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. A footnote states that Bonilla named Judge Hamilton as a defendant in three of the cases but made no specific allegations against her in them.

Disposition

Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases. The court noted Bonilla’s extensive history of filing similar frivolous cases, including filings involving other judges.

The authoritative version

Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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