Bonilla v. Mendocino County Superior Court
- Phyllis Hamilton
- 4:25-cv-06899
- 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 legal bars to the lawsuits.
The order affected Steven Wayne Bonilla and the multiple § 1983 cases he filed. The court dismissed those cases with prejudice, terminated pending motions, closed the cases, and directed the clerk to return later submissions without filing them.
What happened
In Steven Wayne Bonilla v. Judge Jeffrey A. Thompson et al., Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against federal judges, state judges, and state courts. He challenged his conviction and the handling of other cases.
The court ruled that Bonilla could not proceed without paying the filing fees because his allegations did not show imminent danger of serious physical injury when he filed. The court also said that, even if he could proceed without paying, the lawsuits were barred by several legal doctrines. It dismissed the cases with prejudice, terminated all pending motions, and closed the cases.
Judge Phyllis J. Hamilton also declined to recuse herself, explaining that the repetitive and frivolous filings did not reasonably question her impartiality. She ordered the clerk to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Mendocino County Superior Court · No. 4:25-cv-06899
- 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 opinion lists numerous case numbers, including 25-cv-6353-PJH and 25-cv-6847-PJH through 25-cv-7158-PJH. The complaints were nearly identical. Bonilla named various federal judges, state judges, and state courts as defendants and sought relief concerning his underlying conviction or the way other state and federal court cases had been handled.
The opinion states that Bonilla is a condemned prisoner with a pending federal petition challenging his custody in the same district, where he has appointed counsel. It also states that he is represented by counsel in state-court proceedings. The opinion further notes his history of filing similar cases.
Ruling on filing-fee status and dismissal
The court explained that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless 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. Bonilla therefore could not proceed without paying the filing fees.
The court added 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 separately identify which doctrine applies to which claim or case. The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases.
Recusal and case closure
The court also addressed whether the judge should step aside because of the repetitive and allegedly frivolous filings. It concluded that these were not cases in which the judge’s impartiality might reasonably be questioned. The opinion notes that Bonilla named the judge as a defendant in three of the cases but made no specific allegations against her.
Judge Phyllis J. Hamilton ordered the clerk to return, without filing, any further documents Bonilla submitted in the closed cases. The order was entered on August 26, 2025.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.