Bonilla v. Mendez
- Phyllis Hamilton
- 4:25-cv-07052
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Thompson, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and identifying additional legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The clerk was ordered to close the cases, terminate pending motions, and return future submissions in those cases without filing them.
What happened
Bonilla v. Thompson involved multiple complaints filed by Steven Wayne Bonilla, a state prisoner proceeding without a lawyer. The complaints raised nearly identical claims against federal judges, state judges, and state courts and sought relief related to his conviction or the handling of other cases.
The court found that Bonilla could not proceed without paying the filing fees because his allegations did not show that he faced an immediate danger of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without paying, the lawsuits would be barred by several legal rules concerning challenges to convictions, ongoing state proceedings, and the authority of federal courts.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate pending motions and close the cases, and directed the clerk to return future documents submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Mendez · No. 4:25-cv-07052
- Phyllis Hamilton
- Aug. 26, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a law allowing certain civil-rights claims against government officials. 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 way his other cases had been handled. The order also notes that Bonilla had a pending federal petition challenging his conviction, with appointed counsel, and was represented by counsel in state post-conviction proceedings.
Proceeding Without Paying Filing Fees
The court stated that Bonilla had previously been barred from proceeding without paying filing fees under the federal prisoner-litigation statute, 28 U.S.C. § 1915(g). That statute permits a prisoner subject to the bar to proceed without paying only if the complaint shows that the prisoner was facing imminent danger of serious physical injury when the complaint was filed. The court found that the allegations in these complaints did not show such danger. Bonilla therefore could not proceed without paying the filing fees.
Additional Grounds for Dismissal
The court further held 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 does not analyze the underlying claims on their merits; it dismisses the cases based on the filing-fee restriction and the additional legal bars.
The court also stated that the repetitive and allegedly frivolous filings did not provide a basis to question the undersigned judge’s impartiality. The order noted that Bonilla had named the judge as a defendant in three of the cases but had made no specific allegations against her.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submits in the closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.