Bonilla v. Byrd
- Phyllis Hamilton
- 4:25-cv-07012
- U.S. District Court · Northern District of California
- 3
In Steven Wayne Bonilla v. Judge Jeffrey A. Thompson, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying fees and his claims were barred.
Steven Wayne Bonilla and the defendants in the multiple related cases were affected. The cases were dismissed with prejudice, pending motions were terminated, the cases were closed, and future documents submitted in them were to be returned without filing.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights cases 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 found that Bonilla had previously been barred from filing without paying the filing fee unless he faced an immediate serious physical danger, and that his complaints did not show such danger when filed. The court also said that, even if he could file without paying, several legal rules barred the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, rejected the concern that her impartiality could reasonably be questioned, terminated all pending motions, and ordered the clerk to close the cases and return future documents without filing them.
The detailed version
- Bonilla v. Byrd · No. 4:25-cv-07012
- Phyllis Hamilton
- Aug. 26, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, a federal law allowing certain civil-rights claims. The complaints were filed without a lawyer and presented nearly identical allegations. Bonilla named various federal judges, state judges, and state courts as defendants. The opinion says he sought relief concerning his underlying conviction and the handling of his other state and federal cases.
The opinion also notes that Bonilla is a condemned prisoner with a pending federal petition in this court challenging his conviction or sentence, for which he has appointed counsel. It further states that he is represented by counsel in state court proceedings challenging his conviction or sentence.
Filing-fee restriction
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger at the time of filing. Bonilla therefore could not proceed without paying the filing fee.
Other barriers to the lawsuits
The court added that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion states these rules as additional reasons the lawsuits could not proceed, but it does not separately analyze each rule in detail.
Ruling and case management
The court dismissed the cases with prejudice. It also concluded that the repetitive and allegedly frivolous filings did not create a reasonable basis to question Judge Hamilton's impartiality. 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.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.