Sonoma County Superior Court v. Bonilla
- Phyllis Hamilton
- 4:25-cv-02617
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Judge Lydia Villarreal, Judge Hamilton dismissed the related civil-rights cases with prejudice.
Steven Wayne Bonilla’s multiple related civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk not to file further documents Bonilla submitted in them.
What happened
In Steven Wayne Bonilla v. Judge Lydia Villarreal et al., Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against judges and other officials. He sought relief related to his conviction and the handling of his other court cases.
The court said Bonilla could not proceed without paying the filing fee because he had been barred from proceeding without fees unless he showed imminent danger of serious physical injury, which his complaints did not show. The court also said the cases would be barred by other legal rules even if he could proceed without paying.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return future documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Sonoma County Superior Court v. Bonilla · No. 4:25-cv-02617
- Phyllis Hamilton
- Mar. 27, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints representing himself under 42 U.S.C. § 1983, a law allowing civil-rights claims against state actors. The complaints were nearly identical. They named various federal and state judges and other officials and sought relief concerning Bonilla’s underlying conviction or the handling of his other state and federal court cases.
The opinion states that Bonilla is a condemned prisoner with a pending federal petition challenging his confinement and has counsel in that federal matter. It also states that he is represented by counsel in state-court proceedings.
Court’s analysis
The court ruled that, to the extent Bonilla sought permission to proceed without paying the filing fee, he was disqualified under 28 U.S.C. § 1915(g). That statute generally bars a prisoner with the relevant filing history from proceeding without paying unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger.
The court further stated that, even if an application to proceed without paying were granted, the lawsuits would be barred under the legal rules identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion also rejected the suggestion that the repetitive and frivolous nature of the filings created a reasonable basis to question the assigned judge’s impartiality.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.
Scope and naming note
The supplied case name, “Sonoma County Superior Court v. Bonilla,” does not match the caption in the opinion. The opinion captions the matters as Steven Wayne Bonilla v. Judge Lydia Villarreal et al. and lists multiple related case numbers.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.