Bonilla v. Fleming
- Phyllis Hamilton
- 4:25-cv-07444
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Desautels, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla showed no imminent danger and the suits faced legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also terminated all pending motions, closed the cases, and directed the clerk to return future documents submitted in those closed cases without filing them.
What happened
In Steven Wayne Bonilla v. Judge Tara M. Desautels et al., Steven Wayne Bonilla, a condemned state prisoner, filed multiple similar civil-rights cases without a lawyer. He sued various federal judges, state judges, and other government officials over his conviction and the handling of his other court cases.
The court said Bonilla was barred from proceeding without paying the filing fee because his allegations did not show that he faced imminent danger of serious physical injury when he filed the complaints. The court also said that, even if he were allowed to proceed without paying, the lawsuits would be barred by several legal doctrines and statutes.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that further documents Bonilla submitted in those closed cases be returned without filing.
The detailed version
- Bonilla v. Fleming · No. 4:25-cv-07444
- Phyllis Hamilton
- Sept. 25, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple nearly identical civil-rights complaints under 42 U.S.C. § 1983. Section 1983 provides a way to seek relief for certain violations of federal rights by government officials. The complaints named various federal judges, state judges, and other government officials as defendants. Bonilla sought relief concerning his underlying conviction and the way his other state and federal cases had been handled.
The opinion states that Bonilla had a pending federal petition challenging his conviction in the same district, with appointed counsel, and was also represented by counsel in state-court proceedings concerning his conviction.
Proceeding Without Paying the Filing Fee
The court addressed Bonilla’s attempt to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior cases generally may not proceed without paying unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court said Bonilla had already been disqualified from proceeding without paying under that statute.
The court found that the allegations in these complaints did not show imminent danger at the time of filing. Bonilla therefore could not proceed without paying the filing fee.
Other Legal Bars
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal doctrines or rules identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not decide the underlying validity of Bonilla’s conviction or the merits of his claims against the defendants.
Recusal Issue
The court also stated that the cases did not present circumstances in which the undersigned judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The opinion notes that Bonilla named the judge as a defendant in two of the cases.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered 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.