Bonilla v. Ashley
- Phyllis Hamilton
- 4:25-cv-06954
- U.S. District Court · Northern District of California
- 3
Bonilla v. Thompson: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without prepaying fees and his claims were barred.
Steven Wayne Bonilla and the defendants in the multiple listed cases, including federal judges, state judges, and state courts.
What happened
In Bonilla v. Judge Jeffrey A. Thompson et al., Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights cases against federal judges, state judges, and state courts. He sought relief concerning his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without prepaying filing fees because he had been disqualified from proceeding without fees and had not shown that he faced an imminent danger of serious physical injury when he filed. The court also stated that the lawsuits would be barred even if his applications to proceed without fees were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, closed the cases, and directed the clerk to return future documents Bonilla submits in those closed cases without filing them.
The detailed version
- Bonilla v. Ashley · No. 4:25-cv-06954
- Phyllis Hamilton
- Aug. 26, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The complaints presented nearly identical claims and named various federal judges, state judges, and state courts as defendants. Bonilla sought relief concerning his underlying conviction and the handling of his other state and federal cases.
The opinion states that Bonilla is a condemned prisoner with a pending federal petition challenging his detention or conviction in the same court, where he has appointed counsel. It also states that he is represented by counsel in state-court proceedings.
Proceeding Without Prepaying Filing Fees
The court explained that Bonilla had previously been disqualified from proceeding without prepaying filing fees under 28 U.S.C. § 1915(g). That statute allows a disqualified prisoner to proceed without prepaying fees only if the complaint shows that the prisoner was in imminent danger of serious physical injury when the complaint was filed.
The court found that the allegations in these complaints did not show imminent danger at the time of filing. Bonilla therefore could not proceed without prepaying filing fees.
Other Bars to the Lawsuits
The court further stated that, even if Bonilla’s applications to proceed without prepaying fees were granted, the lawsuits would be barred under the rules and precedents identified in the opinion, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.
The opinion also addressed Bonilla’s naming of the undersigned judge as a defendant in three of the cases. The court concluded that these were not cases in which the judge’s impartiality could reasonably be questioned based on the repetitive and frivolous nature of the filings. The court cited the principle that, absent legitimate grounds for recusal, a judge has a duty to decide assigned cases.
Disposition
The court dismissed the multiple cases with prejudice. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submits in the closed cases.
Scope of the Ruling
The opinion resolved the cases based on Bonilla’s inability to proceed without prepaying filing fees and the additional legal bars the court identified. It did not grant the requested relief concerning Bonilla’s conviction or the handling of his other cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.