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 after finding Bonilla could not proceed under fee-waiver rules and that legal bars applied.
Steven Wayne Bonilla and the multiple civil-rights cases he filed; the cases were dismissed with prejudice, pending motions were terminated, and the cases were closed.
What happened
In Bonilla v. Judge Jeffrey A. Thompson et al., Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under a civil-rights statute. He named federal judges, state judges, and state courts, and sought relief concerning his conviction and the handling of his other cases.
The court found that Bonilla had not shown he was in immediate danger of serious physical injury when he filed the complaints, so he could not proceed without paying the required filing fees. The court also said that, even if he could proceed that way, the lawsuits would be barred by several legal rules and prior decisions. It dismissed the cases with prejudice.
Judge Phyllis J. Hamilton also stated that the filings did not provide a basis to reasonably question her impartiality. She directed the clerk to end all pending motions, close the cases, and return any further documents Bonilla submitted in those 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, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The caption lists numerous related case numbers. 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 with a pending federal petition challenging his conviction or imprisonment in the same court, where he has appointed counsel. It also states that he is represented by counsel in state-court proceedings challenging his conviction.
Filing-fee status and legal bars
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That provision permits such a prisoner to proceed without paying only if he shows that he was facing an immediate danger of serious physical injury when he filed the complaint.
The court found that the allegations did not show such an immediate danger. It therefore held that Bonilla could not proceed without paying the filing fee. The court further stated that, even if an application to proceed without paying the fee were granted, the lawsuits would be barred under the legal rules and decisions identified as Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.
Ruling
The court dismissed the cases with prejudice. The opinion did not decide whether Bonilla’s underlying challenges to his conviction or to the handling of his other cases were legally correct; it disposed of the cases based on filing-fee restrictions and stated legal bars.
The court also stated that the repetitive and frivolous filings did not create a reasonable question about the undersigned judge’s impartiality. The clerk was ordered to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in the closed cases.
Judge Phyllis J. Hamilton signed the order on August 26, 2025.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.