Bonilla v. San Joaquin County Superior Court
- Phyllis Hamilton
- 4:25-cv-05200
- U.S. District Court · Northern District of California
- 3
In Bonilla v. U.S. District Court Judges, Judge Hamilton dismissed multiple cases with prejudice because Bonilla could not proceed without fees and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, and the clerk was directed to close them and return later submissions without filing them.
What happened
Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights cases against federal and state courts and government agencies. He sought relief related to his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying filing fees because his prior filings disqualified him from that status, and his allegations did not show an immediate danger of serious physical injury when he filed. The court also said the lawsuits were barred by several legal rules, even if his requests to proceed without fees were granted.
The court dismissed all of the cases with prejudice, terminated the pending motions, and directed the clerk to close the cases and return future submissions without filing them. Judge Phyllis J. Hamilton also declined to treat the repetitive filings as a reason to question her impartiality.
The detailed version
- Bonilla v. San Joaquin County Superior Court · No. 4:25-cv-05200
- Phyllis Hamilton
- June 30, 2025
Background
Steven Wayne Bonilla, a state prisoner facing a death sentence, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints were nearly identical. They named various federal and state courts and government agencies and sought relief concerning Bonilla’s underlying conviction or the way his other cases had been handled.
The opinion states that Bonilla had a pending federal petition challenging his detention, with appointed counsel, and was represented by counsel in state-court proceedings. The opinion also notes that he had an extensive history of filing similar cases.
Court’s analysis
The court addressed whether Bonilla could proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the relevant prior dismissals generally may not proceed without fees unless the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court ruled that Bonilla’s allegations did not show such a danger, so he could not proceed without paying the fees.
The court further ruled that, even if an application to proceed without fees were granted, the lawsuits would be barred under the legal rules identified in the opinion, including rules concerning challenges to criminal convictions, interference with ongoing proceedings, attacks on federal court judgments, and related limits on these claims.
The court also addressed Bonilla’s naming of the Northern District as a defendant in two cases and concluded that the repetitive and allegedly frivolous nature of the filings did not provide a reasonable basis to question the judge’s impartiality.
Disposition
The court dismissed the cases with prejudice. It directed the clerk 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. Judge Phyllis J. Hamilton signed the order.
Listed cases
The order covers Case Nos. 25-cv-4482-PJH, 25-cv-4527-PJH, 25-cv-4658-PJH, 25-cv-4711-PJH, 25-cv-4894-PJH, 25-cv-4895-PJH, 25-cv-5198-PJH, 25-cv-5199-PJH, 25-cv-5200-PJH, 25-cv-5248-PJH, 25-cv-5249-PJH, 25-cv-5251-PJH, 25-cv-5252-PJH, 25-cv-5253-PJH, 25-cv-5254-PJH, 25-cv-5255-PJH, 25-cv-5256-PJH, 25-cv-5257-PJH, 25-cv-5295-PJH, 25-cv-5297-PJH, and 25-cv-5300-PJH.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.