Bonilla v. Alameda County District Attorney
- Phyllis Hamilton
- 4:25-cv-07448
- U.S. District Court · Northern District of California
- 3
Bonilla v. Desautels: Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and legal barriers to the lawsuits.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice, and the clerk was directed to close them and return future submissions without filing them.
What happened
Steven Wayne Bonilla v. Judge Tara M. Desautels et. al. involved multiple complaints by Bonilla, a state prisoner, against various federal judges, state judges, and other government officials. He filed the complaints without a lawyer under the federal civil-rights statute and sought relief related to his conviction and 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 imminent danger of serious physical injury when he filed the complaints. The court also stated that, even if he had been allowed to proceed without paying, the lawsuits would be barred by several legal rules identified in the order.
The court dismissed the cases with prejudice, terminated all pending motions, and directed the clerk to close the cases and return future documents without filing them. Judge Phyllis J. Hamilton also rejected the suggestion that her impartiality could reasonably be questioned because of the repetitive filings.
The detailed version
- Bonilla v. Alameda County District Attorney · No. 4:25-cv-07448
- Phyllis Hamilton
- Sept. 25, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute. 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 or the way his other state and federal cases had been handled.
The order notes that Bonilla is a condemned prisoner with a pending federal petition challenging his custody in the same court, where he has appointed counsel. It also states that he is represented by counsel in state-court proceedings involving a similar petition.
Reasoning
The court addressed Bonilla's requests to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified under the statute may proceed without paying only if he was in imminent danger of serious physical injury when he filed the complaint. The court stated that Bonilla had been disqualified from proceeding without paying fees and that his allegations did not show the required imminent danger.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules identified in the order, including rules concerning challenges to criminal convictions, interference with ongoing proceedings, certain attacks on federal-court proceedings, and claims against federal judges. The court also noted Bonilla's extensive history of filing similar cases.
The order separately addressed the fact that Bonilla named Judge Hamilton as a defendant in two of the cases. It concluded that the repetitive and allegedly frivolous nature of the filings did not provide a reasonable basis to question the judge's impartiality. The court cited the principle that, absent legitimate reasons for recusal, a judge has a duty to decide cases assigned to that judge.
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. The order was signed by Judge Phyllis J. Hamilton.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.