Bonilla v. Alameda County et. al.
- Phyllis Hamilton
- 4:25-cv-09526
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Alameda County, Judge Hamilton dismissed four related civil-rights cases with prejudice after finding Bonilla could not obtain a filing-fee waiver and the suits were legally barred.
Steven Wayne Bonilla’s four related § 1983 cases against Alameda County and the other named government officials, including various federal and state judges; the order also affects any further documents submitted in those closed cases.
What happened
Steven Wayne Bonilla v. Alameda County et. al. involved four related cases in which Bonilla, a state prisoner proceeding without a lawyer, brought nearly identical civil-rights complaints against various federal judges, state judges, and other government officials. He sought relief concerning his conviction and the handling of his other cases.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed. The court found that his complaints did not show such danger. It also said that, even if he had been allowed to proceed without paying fees, legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed all four cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that further documents Bonilla submitted in those closed cases be returned without filing.
The detailed version
- Bonilla v. Alameda County et. al. · No. 4:25-cv-09526
- Phyllis Hamilton
- Dec. 22, 2025
Background
Steven Wayne Bonilla, identified in the order as a state prisoner and condemned prisoner, filed four related civil-rights complaints without a lawyer under 42 U.S.C. § 1983. 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 or the way his other state and federal cases had been handled.
The order also notes that Bonilla had a pending federal petition challenging his conviction in the same court with appointed counsel and was represented by counsel in state court proceedings.
Filing-fee status
To the extent Bonilla sought permission to proceed without paying filing fees, the court held that 28 U.S.C. § 1915(g) disqualified him from doing so unless he showed that he was under an immediate danger of serious physical injury when he filed the complaint. The court found that his allegations did not show such danger.
Other grounds for dismissal
The court stated that, even if Bonilla had been granted permission to proceed without paying filing fees, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not decide the underlying validity of Bonilla’s claims; it concluded that these threshold legal barriers prevented the cases from proceeding.
Ruling and case status
Judge Phyllis J. Hamilton dismissed the four cases with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.
The court additionally rejected the suggestion that the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and frivolous filings. The order states that the judge had a duty to sit in cases assigned to the judge absent legitimate reasons for recusal.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.