Bonilla v. Dawn
- Phyllis Hamilton
- 4:25-cv-07157
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Desautels, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding Bonilla could not proceed without paying filing fees.
Steven Wayne Bonilla, a state prisoner who filed multiple civil-rights cases without a lawyer; the cases were dismissed with prejudice, and future submissions in them were ordered returned without filing.
What happened
Steven Wayne Bonilla, a condemned state prisoner, filed multiple similar civil-rights lawsuits without a lawyer against federal judges, state judges, and other government officials. He sought relief connected to his conviction and the handling of his other court cases.
The court said Bonilla had previously been barred from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury. The complaints did not show that danger. The court also said the lawsuits would be barred by several legal rules even if he could proceed without paying those fees.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was ordered to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Dawn · No. 4:25-cv-07157
- Phyllis Hamilton
- Sept. 25, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute for claims against government officials. The complaints presented nearly identical claims and named various federal judges, state judges, and other government officials as defendants. Bonilla sought relief concerning his underlying conviction and the way state and federal courts had handled his other cases.
The opinion states that Bonilla had a pending federal petition challenging his conviction with appointed counsel and was also represented by counsel in state-court proceedings. The court also noted his extensive history of filing similar cases.
Reasons for the ruling
The court addressed Bonilla’s ability to proceed in forma pauperis, meaning without paying the required filing costs in advance. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals cannot proceed this way unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court held that Bonilla’s allegations did not show such danger, so he could not proceed in forma pauperis.
The court further stated that, even if an application to proceed in forma pauperis were granted, the lawsuits would be barred under rules and doctrines identified in the opinion, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not resolve the underlying civil-rights allegations on their merits.
Bonilla named Judge Hamilton as a defendant in two of the cases. Judge Hamilton concluded that the repetitive and frivolous nature of the filings did not provide a reasonable basis to question her impartiality and cited the duty of an assigned judge to hear cases absent legitimate grounds for recusal.
Disposition
Judge Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in those closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.