Bonilla v. Judge Freeman
- Phyllis Hamilton
- 4:25-cv-07047
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Thompson, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and his claims were barred.
Steven Wayne Bonilla’s multiple federal civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk to return later submissions without filing them.
What happened
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights lawsuits against federal judges, state judges, and state courts. The lawsuits challenged his conviction or how his other cases had been handled. The order covered the cases listed under Steven Wayne Bonilla v. Judge Jeffrey A. Thompson et al.
The court ruled that Bonilla could not proceed without paying the filing fees because he had previously been disqualified from that status and his complaints did not show an immediate danger of serious physical injury. The court also said that, even if he could proceed without paying, the lawsuits were barred by rules governing challenges to convictions, ongoing state proceedings, and claims against courts and judges. The court dismissed the cases with prejudice, ended all pending motions, and closed the cases.
Judge Phyllis J. Hamilton also stated that the repetitive and frivolous filings did not provide a reasonable basis to question her impartiality. The clerk was directed to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Judge Freeman · No. 4:25-cv-07047
- Phyllis Hamilton
- Aug. 26, 2025
Background
Steven Wayne Bonilla, described as a state prisoner and a condemned prisoner, filed multiple pro se civil-rights complaints under 42 U.S.C. § 1983. “Pro se” means he filed without a lawyer. The order lists numerous related case numbers, including 25-cv-6353-PJH, 25-cv-6847-PJH, 25-cv-6849-PJH, and others. The complaints presented nearly identical claims against various federal judges, state judges, and state courts. They sought relief concerning Bonilla’s underlying conviction or the handling of his other cases.
The court also noted that Bonilla had a pending federal habeas petition in the same court with appointed counsel and was represented by counsel in state-court habeas proceedings. The opinion further stated that Bonilla had an extensive history of filing similar cases.
Ruling on filing fees
The court ruled that Bonilla could not proceed in these cases without paying the filing fees under 28 U.S.C. § 1915(g). That statute generally disqualifies a prisoner from proceeding without fees after qualifying prior filings, unless the complaint shows that the prisoner faced imminent danger of serious physical injury when it was filed. The court found that Bonilla’s allegations did not show such danger. Therefore, he could not proceed without paying the filing fees.
Additional bars and disposition
The court stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the principles identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order does not provide a separate claim-by-claim analysis of those grounds. The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases.
Impartiality and case closure
The court stated that the repetitive and frivolous nature of the filings did not create a reasonable question about the undersigned judge’s impartiality. It also noted that Bonilla named the undersigned judge as a defendant in three of the cases but made no specific allegations against that judge. The clerk was directed to return, without filing, any further documents Bonilla submitted in the closed cases.
Judge
The order was signed by United States District Judge Phyllis J. Hamilton on August 26, 2025.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.