Bonilla v. Federal Public Defender's Office
- Phyllis Hamilton
- 4:25-cv-07449
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Desautels, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and identifying other legal barriers.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, his pending motions were terminated, the cases were closed, and future documents submitted in those cases were to be returned without filing.
What happened
In Steven Wayne Bonilla v. Judge Tara M. Desautels et al., Bonilla, a condemned state prisoner, filed multiple civil-rights lawsuits without a lawyer. He named federal judges, state judges, and other government officials, and sought relief related to his conviction or the handling of his other cases.
The court ruled 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 court also said that, even if he could proceed without those payments, the lawsuits would be barred by other legal rules. It dismissed the cases with prejudice, ended all pending motions, and closed the cases.
Judge Phyllis J. Hamilton also rejected the argument that her impartiality could reasonably be questioned because of Bonilla’s repeated filings, including that he named her as a defendant in two cases. She ordered the clerk to return future documents submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Federal Public Defender's Office · No. 4:25-cv-07449
- Phyllis Hamilton
- Sept. 25, 2025
Background
Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights complaints under 42 U.S.C. § 1983. The complaints named various federal judges, state judges, and other government officials. They sought relief concerning Bonilla’s underlying conviction or the way his state and federal cases had been handled. The opinion also notes that Bonilla had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state proceedings.
Filing-fee status
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court concluded that the allegations did not show such imminent danger. Bonilla therefore could not proceed without paying the filing fees.
Other barriers and disposition
The court further stated that, even if Bonilla’s applications to proceed without paying the filing 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 opinion did not decide the underlying merits of Bonilla’s claims. It dismissed the cases with prejudice, directed the clerk to terminate all pending motions, and ordered the clerk to close the cases.
Impartiality and filing restrictions
The court rejected the contention that the judge’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. The opinion notes that Bonilla named Judge Hamilton as a defendant in two of the cases. The clerk was instructed to return, without filing, any further documents Bonilla submitted in these closed cases. The court also noted Bonilla’s extensive history of filing similar cases.
Outcome
The court dismissed all listed cases with prejudice and closed them. This was a procedural disposition based on filing-fee eligibility and other legal barriers, rather than a decision on whether Bonilla’s underlying claims were legally correct.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.