Bonilla v. Dabel
- Phyllis Hamilton
- 4:25-cv-06953
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Thompson, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and the lawsuits were legally barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice and closed. The order also terminated pending motions and directed the clerk not to file further documents in those cases.
What happened
In Bonilla v. Judge Jeffrey A. Thompson et al., Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer. He sued various federal judges, state judges, and state courts over his conviction and how other cases were handled.
The court said Bonilla had previously been barred from proceeding without paying the filing fee unless he showed an immediate danger of serious physical injury. The complaints did not show that danger. The court also said that, even if Bonilla had been allowed to proceed without paying, the lawsuits were barred by several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return any further documents without filing them. The court also declined to question Judge Hamilton’s impartiality based on the repetitive filings.
The detailed version
- Bonilla v. Dabel · No. 4:25-cv-06953
- Phyllis Hamilton
- Aug. 26, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints presented nearly identical claims and named various federal judges, state judges, and state courts as defendants. The court said Bonilla sought relief concerning his underlying conviction and the handling of his other state and federal cases.
The order also noted that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings.
Court’s reasoning
The court explained that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger, so Bonilla could not proceed without paying the filing fee.
The court further stated that, even if an application to proceed without paying had been 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 order did not provide a separate claim-by-claim analysis of those legal bars.
The court also addressed judicial impartiality. It concluded that the repetitive and allegedly frivolous filings did not create a reasonable question about the undersigned judge’s impartiality. The court noted that Bonilla named Judge Hamilton as a defendant in three cases but made no specific allegations against her.
Disposition
The court dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in the closed cases.
Classification basis
This is a procedural order because the court disposed of the cases based on filing-fee eligibility and other legal bars without deciding the underlying civil-rights claims on their merits.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.