Bonilla v. Alameda County et. al.
- Phyllis Hamilton
- 4:25-cv-10598
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. Alameda County, Judge Hamilton dismissed four civil-rights cases with prejudice because Bonilla could not proceed without fees and his claims faced legal bars.
Steven Wayne Bonilla’s four civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk to return future submissions in those cases without filing them.
What happened
In Steven Wayne Bonilla v. Alameda County, Steven Wayne Bonilla, a state prisoner, filed four nearly identical civil-rights lawsuits without a lawyer. He sued various federal judges, state judges, and other government officials, seeking relief related to his conviction and the handling of other court cases.
The court said Bonilla was barred from proceeding without paying the filing fees because he had previously filed three or more cases dismissed as frivolous, and his complaints did not show that he faced imminent danger of serious physical injury. The court also said the lawsuits would be barred for other legal reasons even if he could proceed without paying fees.
Judge Phyllis J. Hamilton dismissed all four cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases. The clerk was also instructed to return, without filing, any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Alameda County et. al. · No. 4:25-cv-10598
- Phyllis Hamilton
- Dec. 22, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and condemned prisoner, filed four nearly identical complaints without a lawyer under 42 U.S.C. § 1983, the federal law that permits certain civil-rights lawsuits against government officials. The defendants included various federal judges, state judges, and other government officials. Bonilla sought relief concerning his underlying conviction and the way other state and federal cases had been handled.
The opinion states that Bonilla had a pending federal petition challenging his custody in the same court, with appointed counsel, and was represented by counsel in state-court proceedings involving a similar petition.
Filing-fee status and legal bars
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying filing fees because of his history of filing qualifying cases, unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such imminent danger.
The court further stated that, even if Bonilla had been allowed to proceed without paying filing fees, the lawsuits would be barred under the legal rules discussed 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 explaining which cited rule applied to which allegation.
Recusal
The court also addressed whether the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and allegedly frivolous filings. Citing a Ninth Circuit decision, the court stated that, without legitimate grounds for recusal, a judge has a duty to decide cases assigned to that judge. The court concluded that these cases did not require recusal.
Ruling
Judge Phyllis J. Hamilton dismissed all four 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 submitted in these closed cases.
The order does not state that the court reached the merits of Bonilla’s underlying conviction-related claims. The disposition rested on the filing-fee restriction and the additional legal bars identified by the court.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.