Bonilla v. Clay
- Phyllis Hamilton
- 4:25-cv-07011
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Clay, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because Bonilla could not proceed without paying fees and his claims were barred.
Steven Wayne Bonilla, whose multiple lawsuits were dismissed with prejudice, and the federal judges, state judges, and state courts named as defendants. The order also directs the clerk to terminate pending motions, close the cases, and return future submissions without filing them.
What happened
In Bonilla v. Clay, Steven Wayne Bonilla, a state prisoner representing himself, filed many nearly identical civil-rights lawsuits against federal judges, state judges, and state courts. He sought relief concerning his conviction and how other state and federal court cases were handled.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed the complaints. The court found no such danger. It also said that, even if he could proceed without paying fees, legal rules and prior decisions independently barred these lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return any additional documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Clay · No. 4:25-cv-07011
- 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 order covers the related cases listed in the caption. The complaints were nearly identical 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 court cases.
The order states that Bonilla is a condemned prisoner who has a pending federal petition challenging his custody in the same court with appointed counsel. It also states that he is represented by counsel in state court proceedings concerning his custody.
Reasoning
The court explained that Bonilla had already 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 fees only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that the allegations did not show such danger.
The court further stated that, even if an application to proceed without paying fees were 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 also rejected the apparent basis for questioning Judge Hamilton’s impartiality, explaining that the repetitive and frivolous nature of the filings did not provide a reasonable basis for recusal. A footnote states that Bonilla named Judge Hamilton as a defendant in three of the cases but made no specific allegations against her in those cases.
Ruling
Judge Phyllis J. Hamilton dismissed the 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 submitted in the closed cases.
Classification
This is a procedural order because the court dismissed the cases based on filing-fee restrictions and other threshold 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.