Bonilla v. Penny
- Phyllis Hamilton
- 4:25-cv-06958
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Thompson, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and citing legal barriers.
Steven Wayne Bonilla and the multiple cases he filed against various federal judges, state judges, and state courts.
What happened
In Steven Wayne Bonilla v. Judge Jeffrey A. Thompson and others, Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights cases without a lawyer. He challenged his conviction and the handling of other cases by federal and state courts.
The court said Bonilla could not proceed without paying the filing fee because his allegations did not show that he faced imminent danger of serious physical injury when he filed. The court also said the lawsuits would be barred by several legal rules even if he were allowed to proceed without paying.
Judge Phyllis J. Hamilton dismissed all of the cases with prejudice, meaning the cases were closed on a final basis. The clerk was ordered to end all pending motions, close the cases, and return any further filings in them without filing them.
The detailed version
- Bonilla v. Penny · No. 4:25-cv-06958
- Phyllis Hamilton
- Aug. 26, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute for claims against state actors. He filed the cases without a lawyer and presented nearly identical claims. The defendants included various federal judges, state judges, and state courts.
The complaints sought relief concerning Bonilla’s underlying conviction and the way his other cases had been handled by state and federal courts. The opinion also states that Bonilla had a pending federal petition challenging his detention in the same court, with appointed counsel, and was represented by counsel in state-court proceedings.
Proceeding Without Paying the Filing Fee
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute permits a prisoner with the relevant filing history to proceed without paying 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 did not show imminent danger at the time of filing. It therefore concluded that Bonilla could not proceed without paying the filing fee.
Other Bars to the Lawsuits
The court further stated that, even if Bonilla’s request 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 opinion did not reach the underlying validity of Bonilla’s conviction or otherwise decide the merits of his claims.
Ruling
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.
The court additionally stated that the repetitive and frivolous nature of the filings did not provide a basis to reasonably question the undersigned judge’s impartiality. It did not separately describe this statement as a ruling on a recusal motion.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.