Bonilla v. Reynolds
- Phyllis Hamilton
- 4:25-cv-07445
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Desautels, Judge Hamilton dismissed multiple civil-rights lawsuits with prejudice after finding no imminent danger and identifying procedural bars.
Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice. The order also directs the clerk to close those cases, terminate pending motions, and return future submissions in them without filing.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights lawsuits without a lawyer against federal judges, state judges, and other government officials. He sought relief concerning his conviction and the handling of other court cases.
The court found that Bonilla could not proceed without paying the filing fees because he had been disqualified from that status and had not shown that he faced imminent danger of serious physical injury when he filed. The court also said the lawsuits would be barred by several legal rules even if that status were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered the clerk to return future filings in those closed cases without filing them.
The detailed version
- Bonilla v. Reynolds · No. 4:25-cv-07445
- Phyllis Hamilton
- Sept. 25, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple pro se complaints under 42 U.S.C. § 1983. A pro se litigant represents himself without a lawyer. The complaints were nearly identical and named various federal judges, state judges, and other government officials as defendants. Bonilla sought relief related to his underlying conviction or to the way state and federal courts handled his other cases.
The opinion states that Bonilla had a pending federal habeas petition in the same court with appointed counsel and was represented by counsel in state habeas proceedings.
Inability to Proceed Without Paying Filing Fees
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding in forma pauperis, meaning without paying the filing fee, unless he showed that he was under imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show imminent danger at the relevant time.
Additional Bars Identified by the Court
The court further stated that, even if an application to proceed without paying the filing fee 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 opinion did not resolve the underlying conviction-related or court-handling claims on their merits; it identified these legal barriers to the lawsuits.
The court also addressed the fact that Bonilla named the presiding judge as a defendant in two of the cases. It concluded that the repetitive and frivolous nature of the filings did not provide a basis to question the judge’s impartiality.
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 the closed cases.
Classification
This is a procedural order because the court dismissed the cases based on filing-fee eligibility and other threshold legal bars rather than deciding the underlying civil-rights claims.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.