Bonilla v. Blum
- Phyllis Hamilton
- 4:25-cv-07049
- U.S. District Court · Northern District of California
- 3
In Steven Wayne Bonilla v. Judge Jeffrey A. Thompson, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because Bonilla did not qualify for fee-waiver status and the suits were barred.
Steven Wayne Bonilla's multiple civil-rights cases against various federal judges, state judges, and state courts 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 condemned state prisoner representing himself, filed multiple nearly identical civil-rights cases against federal judges, state judges, and state courts. He challenged his conviction and the handling of his other cases.
The court found that Bonilla could not proceed without paying filing fees because his allegations did not show an immediate danger of serious physical injury when he filed the complaints. The court also said that, even if he had qualified for that status, several legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed all of the cases with prejudice, terminated the pending motions, closed the cases, and directed the clerk to return future documents submitted in them without filing them.
The detailed version
- Bonilla v. Blum · No. 4:25-cv-07049
- Phyllis Hamilton
- Aug. 26, 2025
Background
Steven Wayne Bonilla, a state prisoner facing a death sentence, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute that allows claims against state actors for violations of federal rights. The complaints presented nearly identical claims and named various federal judges, state judges, and state courts as defendants. Bonilla sought relief concerning his underlying conviction and the way his other state and federal cases had been handled.
The opinion also notes that Bonilla had a pending federal petition challenging his custody in the same court, where he had appointed counsel, and that he was represented by counsel in state-court proceedings.
Filing-fee status
The court stated that Bonilla had previously been disqualified under 28 U.S.C. § 1915(g) from proceeding in forma pauperis, meaning without paying the required filing fees, unless he showed that he was in immediate danger of serious physical injury when he filed the complaint. The court found that these complaints did not show such danger. It therefore held that Bonilla could not proceed under that fee-waiver status.
Other barriers and ruling
The court further stated that, even if Bonilla's applications to proceed without paying filing fees had been granted, the lawsuits would be barred by several legal doctrines and decisions, including rules concerning challenges to criminal convictions, interference with ongoing state proceedings, and attacks on the actions of federal courts. The opinion cited Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.
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 those closed cases. The court also stated that the repetitive and frivolous filings did not provide a basis for questioning the judge's impartiality. A footnote reported that Bonilla had named Hamilton as a defendant in three of the cases but made no specific allegations against her.
Classification basis
This is a procedural order because the court disposed of the cases based on filing-fee eligibility and threshold legal bars rather than 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.