Bonilla v. Brady
- Phyllis Hamilton
- 4:25-cv-07010
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Judge Thompson et al., Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and citing other legal bars.
Steven Wayne Bonilla and the defendants named in the multiple cases, including federal judges, state judges, and state courts.
What happened
In Bonilla v. Judge Jeffrey A. Thompson et al., Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights lawsuits without a lawyer. He sued various federal judges, state judges, and state courts over his conviction and the handling of his other cases.
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 cases. The court also said that, even if he could proceed without paying, the lawsuits would be barred by other legal rules.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and directed the clerk to close the cases and return future documents without filing them.
The detailed version
- Bonilla v. Brady · No. 4:25-cv-07010
- Phyllis Hamilton
- Aug. 26, 2025
Background
Steven Wayne Bonilla, identified by the court as a state prisoner and a condemned prisoner, filed multiple similar complaints without a lawyer under 42 U.S.C. § 1983, a statute that allows certain civil-rights claims against state actors. The complaints named various federal judges, state judges, and state courts as defendants. They sought relief concerning Bonilla’s underlying conviction or the way his other state and federal cases had been handled.
The court noted that Bonilla had a pending federal petition challenging his custody in the same district, with appointed counsel, and was also represented by counsel in state-court proceedings. The court further noted his history of filing similar cases.
Court’s analysis
The court stated that, to the extent Bonilla sought permission to proceed without paying the filing fee, 28 U.S.C. § 1915(g) disqualified him from doing so unless he showed that he was in imminent danger of serious physical injury when he filed his complaints. The court concluded that the allegations did not show such imminent danger. Bonilla therefore could not proceed without paying the filing fee.
The court added that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the rules and decisions cited in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate claim-by-claim explanation of how each cited authority applied.
The court also rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. It cited the rule that, absent legitimate grounds for recusal, a judge has a duty to decide assigned cases. A footnote stated that Bonilla named Judge Hamilton as a defendant in three of the cases but made no specific allegations against her.
Disposition
Judge Phyllis J. Hamilton dismissed the cases 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.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.