Bonilla v. Prosecutor Goodfellow
- Phyllis Hamilton
- 4:25-cv-07788
- 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 legal barriers to the lawsuits.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice and closed. The order also directed the clerk not to file further documents Bonilla submits in those closed cases; it does not state that his separate state or federal habeas proceedings were resolved.
What happened
In Steven Wayne Bonilla v. Judge Tara M. Desautels et al., Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights complaints against judges and other government officials. He sought relief concerning his conviction and the handling of his other cases.
The court found that Bonilla could not proceed without paying the filing fees because his allegations did not show imminent danger of serious physical injury when he filed. The court also said that, even if he could proceed without paying, the lawsuits were barred by several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return future documents without filing them. The court also stated that the repetitive filings did not reasonably question Judge Hamilton’s impartiality.
The detailed version
- Bonilla v. Prosecutor Goodfellow · No. 4:25-cv-07788
- Phyllis Hamilton
- Sept. 25, 2025
Background
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical. They named various federal judges, state judges, and other government officials as defendants and sought relief concerning Bonilla’s underlying conviction or the handling of his other state and federal cases.
The order notes that Bonilla had a pending federal petition concerning his imprisonment in the same court, with appointed counsel, and was represented by counsel in state-court proceedings concerning his imprisonment.
Proceeding Without Paying Filing Fees
The court stated that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). That statute allows a disqualified prisoner to proceed without paying only if the complaint alleges that the prisoner was in imminent danger of serious physical injury when the complaint was filed.
The court found that Bonilla’s allegations did not show imminent danger at the time of filing. It therefore concluded that he could not proceed without paying the filing fees.
Other Legal Bars
The court further stated that, even if an application to proceed without paying 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 order did not separately analyze each complaint or explain which cited legal bar applied to which claim.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any further documents Bonilla submits in these closed cases.
The order additionally stated that the repetitive and frivolous filings did not create a reasonable question about the undersigned judge’s impartiality. It cited the general duty of a judge to sit on assigned cases when no legitimate reason for recusal exists. The order notes that Bonilla named the undersigned judge as a defendant in two of the cases.
Judge
The order was signed by United States District Judge Phyllis J. Hamilton.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.