Bonilla v. Smith
- Phyllis Hamilton
- 4:25-cv-08082
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Desautels, Judge Hamilton dismissed the related civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims were legally barred.
Steven Wayne Bonilla’s related civil-rights cases were dismissed with prejudice. The order ended all pending motions, closed the cases, and directed the clerk to return without filing any further documents submitted in those closed cases.
What happened
In Steven Wayne Bonilla v. Judge Tara M. Desautels et al., Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights lawsuits against federal judges, state judges, and other government officials. He challenged his conviction and how other state and federal court cases were handled.
The court said Bonilla could not proceed without paying the filing fees because he had been disqualified from using the fee-waiver process, 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 barred the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to end all pending motions and close the cases, and ordered that further documents Bonilla submits in those closed cases be returned without filing.
The detailed version
- Bonilla v. Smith · No. 4:25-cv-08082
- Phyllis Hamilton
- Sept. 25, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints were filed in the related cases listed in the order: 25-cv-7050-PJH, 25-cv-7157-PJH, 25-cv-7159-PJH, 25-cv-7443-PJH, 25-cv-7444-PJH, 25-cv-7445-PJH, 25-cv-7447-PJH, 25-cv-7448-PJH, 25-cv-7449-PJH, 25-cv-7450-PJH, 25-cv-7636-PJH, 25-cv-7637-PJH, 25-cv-7787-PJH, 25-cv-7788-PJH, 25-cv-7866-PJH, 25-cv-7946-PJH, 25-cv-8081-PJH, and 25-cv-8082-PJH. He named various federal judges, state judges, and other government officials as defendants. The court said the complaints presented nearly identical claims seeking relief concerning Bonilla’s underlying conviction or the handling of his other cases in state and federal court.
The order also states that Bonilla is a condemned prisoner with a pending federal petition challenging his detention, in which he has appointed counsel, and that he is represented by counsel in state proceedings.
Fee-waiver status and legal bars
The court explained 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 immediate danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger. Therefore, Bonilla could not proceed under the fee-waiver process.
The court further ruled that, even if a fee-waiver application were granted, the lawsuits would be barred under the legal rules identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order states that Bonilla had an extensive history of filing similar frivolous cases.
Recusal issue
The court also rejected any suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The order notes that Bonilla named the judge as a defendant in two of the cases, but it does not find a basis for the judge’s recusal.
Disposition
Judge Phyllis J. Hamilton 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.