Bonilla v. Diedrich
- Phyllis Hamilton
- 4:25-cv-07866
- U.S. District Court · Northern District of California
- 3
In Steven Wayne Bonilla v. Judge Tara M. Desautels, Judge Hamilton dismissed multiple civil-rights cases with prejudice after ruling Bonilla could not proceed without paying filing fees.
Steven Wayne Bonilla and the multiple related civil-rights cases he filed; the order also directs the clerk how to handle future filings in those closed cases.
What happened
In Steven Wayne Bonilla v. Judge Tara M. Desautels, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights cases against federal judges, state judges, and other government officials. He sought relief concerning his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying 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 the lawsuits would be barred by several legal doctrines even if he could proceed without paying fees.
Judge Hamilton dismissed the cases with prejudice, ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return without filing any further documents Bonilla submits in those closed cases.
The detailed version
- Bonilla v. Diedrich · No. 4:25-cv-07866
- Phyllis Hamilton
- Sept. 25, 2025
Background
Steven Wayne Bonilla, a state prisoner and condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983, a federal statute allowing claims against persons acting under state law for violating federal rights. 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 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, where he had appointed counsel. It also states that he was represented by counsel in state proceedings challenging his conviction. The court further noted Bonilla’s extensive history of filing similar cases.
Court’s Analysis
The court addressed Bonilla’s ability to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without paying fees may do so only if the complaint shows that the prisoner was in imminent danger of serious physical injury when the complaint was filed. The court ruled that Bonilla’s allegations did not show such danger, so he could not proceed without paying the filing fee.
The court also stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not provide a separate merits determination of the underlying claims.
The court rejected any suggestion that the assigned judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and allegedly frivolous filings. The opinion notes that Bonilla named the judge as a defendant in two of the cases.
Disposition
The court 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 submits in those closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.