Bonilla v. Inyo County Superior Court
- Phyllis Hamilton
- 4:25-cv-05253
- U.S. District Court · Northern District of California
- 3
In Bonilla v. U.S. District Court Northern District Judges and Court Clerks, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without filing fees and his claims were barred.
Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice; pending motions were terminated, the cases were closed, and further documents submitted in those closed cases were to be returned without filing.
What happened
In Bonilla v. U.S. District Court Northern District Judges and Court Clerks, Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer. He challenged his conviction and the handling of his other cases, naming various federal and state courts and government agencies as defendants.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed that he faced an imminent danger of serious physical injury when he filed the complaints. The court found that his allegations did not show such danger. It also said that, even if he could proceed without paying fees, the lawsuits were barred under several legal doctrines.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases. The court also directed the clerk to return, without filing, any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Inyo County Superior Court · No. 4:25-cv-05253
- Phyllis Hamilton
- June 30, 2025
Background
Steven Wayne Bonilla, a condemned state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983. The complaints presented nearly identical claims and named various federal and state courts and government agencies as defendants. Bonilla sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts.
The order states that Bonilla had a pending federal petition challenging his custody in this court, where he had appointed counsel, and that he was also represented by counsel in state-court proceedings challenging his custody.
Proceeding Without Paying Filing Fees
The court stated that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). That statute allows an exception when a prisoner was in imminent danger of serious physical injury at the time the complaint was filed.
The court found that the allegations did not show imminent danger when Bonilla filed these complaints. It therefore ruled that he could not proceed without paying filing fees.
Other Bars to the Lawsuits
The court further stated that, even if an application to proceed without paying filing fees were granted, the lawsuits would be barred under the doctrines 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 provide a separate claim-by-claim analysis of those doctrines.
The court also rejected any suggestion that the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and allegedly frivolous filings. It cited the rule that, absent legitimate grounds for recusal, a judge has a duty to decide assigned cases.
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 submitted in the closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.