Bonilla v. Schubb
- Phyllis Hamilton
- 4:25-cv-07009
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Judge Thompson, Judge Hamilton dismissed multiple civil-rights cases with prejudice, finding no imminent danger and additional legal bars.
Steven Wayne Bonilla’s multiple civil-rights lawsuits were dismissed with prejudice; the defendants named in those cases were affected by the closure of the cases.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases under a federal law allowing claims against state officials. He named federal judges, state judges, and state courts, and challenged his conviction or how other cases had been handled.
The court found that Bonilla could not waive filing fees because his allegations did not show that he faced imminent danger of serious physical injury when he filed the complaints. The court also said that, even if he could waive the fees, several legal rules barred the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return future documents submitted in them without filing them.
The detailed version
- Bonilla v. Schubb · No. 4:25-cv-07009
- Phyllis Hamilton
- Aug. 26, 2025
Background
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The opinion identifies the cases by numerous case numbers, including 25-cv-6353-PJH, 25-cv-6847-PJH, and others. The complaints were nearly identical. They named various federal judges, state judges, and state courts as defendants and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases.
The opinion states that Bonilla is a condemned prisoner who has a pending federal petition challenging his custody, with appointed counsel, and is represented by counsel in state-court proceedings concerning his conviction.
Filing-fee restriction
The court stated that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed each complaint. The court found that the allegations did not show such imminent danger. Therefore, Bonilla could not proceed without paying the filing fees.
Additional legal bars
The court further concluded that, even if an application to waive the filing fees were granted, the lawsuits would be barred under several legal rules identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each rule’s application to each complaint.
Recusal issue
The court also addressed the fact that Bonilla named the judge who issued the order as a defendant in three of the cases. The court found that the repetitive and frivolous nature of the filings did not provide a reason to question the judge’s impartiality. It stated that, absent legitimate grounds for recusal, a judge has a duty to decide cases assigned to that judge.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.
Scope and uncertainty
The supplied case name says “Bonilla v. Schubb,” but the opinion text’s caption identifies the defendants as “JUDGE JEFFREY A. THOMPSON et al.” This summary follows the caption in the opinion text.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.