Bonilla v. O'Farrell
- Phyllis Hamilton
- 4:25-cv-06849
- U.S. District Court · Northern District of California
- 3
Bonilla v. Thompson: Judge Hamilton dismissed multiple cases with prejudice after finding no imminent danger and other legal bars.
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. Judge Jeffrey A. Thompson et al., Steven Wayne Bonilla, a state prisoner representing himself, filed multiple similar civil-rights lawsuits against federal judges, state judges, and state courts. He challenged his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fee because he had previously been barred from filing without fees unless he faced imminent danger of serious physical injury. The court found that his complaints did not show such danger.
Even if the fee applications were granted, the court said the lawsuits were barred by several legal rules and dismissed all the cases with prejudice. Judge Phyllis J. Hamilton also ordered the clerk to terminate pending motions, close the cases, and return future filings without filing them.
The detailed version
- Bonilla v. O'Farrell · No. 4:25-cv-06849
- Phyllis Hamilton
- Aug. 26, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple similar lawsuits without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute for claims against government actors. The cases named various federal judges, state judges, and state courts as defendants. The complaints sought relief concerning Bonilla’s underlying conviction and the way his other state and federal cases had been handled.
The order also noted that Bonilla had a pending federal petition challenging his imprisonment in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings. The court further noted his history of filing similar cases.
Filing-fee ruling
The court stated that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show imminent danger at the time of filing. As a result, Bonilla could not proceed without paying the filing fee.
Dismissal
The court added that, even if Bonilla’s applications to proceed without paying the filing fee were 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 court therefore dismissed the cases with prejudice.
The court also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. It stated that Bonilla named the judge as a defendant in three of the cases but made no specific allegations against her.
Disposition
The court dismissed the multiple cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any additional documents Bonilla submitted in the closed cases. The order was signed by Judge Phyllis J. Hamilton.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.