Bonilla v. Koehler
- Phyllis Hamilton
- 4:25-cv-08081
- U.S. District Court · Northern District of California
- 3
Bonilla v. Desautels: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla showed no imminent danger and the suits faced legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also directed the clerk to close those cases and return future submissions without filing them.
What happened
In Steven Wayne Bonilla v. Judge Tara M. Desautels et al., Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against judges and other government officials. He sought relief related to his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fees because he had previously been barred from that status under federal law, and his complaints did not show that he faced an immediate danger of serious physical injury when he filed them. The court also said that, even if he could proceed without paying, legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate pending motions and close the cases, and directed the clerk to return future documents submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Koehler · No. 4:25-cv-08081
- Phyllis Hamilton
- Sept. 25, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The complaints named various federal judges, state judges, and other government officials. The court said the complaints presented nearly identical claims seeking relief concerning Bonilla’s underlying conviction or the handling of his other cases.
Filing-Fee Status and Legal Barriers
The court explained that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger, so Bonilla could not proceed without paying the filing fees.
The court added that, even if an application to proceed without paying the filing fees were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis of those barriers.
Ruling
The court dismissed the cases with prejudice. It also rejected the contention that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. The court also noted Bonilla’s extensive history of filing similar cases.
Judge Phyllis J. Hamilton signed the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.