Bonilla v. Rosenberg
- Phyllis Hamilton
- 4:25-cv-05595
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Sacramento County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and his claims were barred.
Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk not to file further documents submitted in them.
What happened
In Bonilla v. Sacramento County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against judges, courts, and law-enforcement officials. He sought relief related to his conviction and the handling of his other court cases.
The court found that Bonilla was disqualified from proceeding without paying filing fees because he had not shown that he faced an immediate danger of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without paying fees, the lawsuits were barred by several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate pending motions and close the cases, and directed the clerk to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Rosenberg · No. 4:25-cv-05595
- Phyllis Hamilton
- July 28, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The order covers numerous related case numbers. Bonilla was also described as a condemned prisoner with a pending federal habeas petition in the same court, where he had appointed counsel, and with counsel in state-court habeas proceedings.
The complaints were nearly identical. They named various federal judges, state judges, state courts, and law-enforcement officials as defendants. The order states that Bonilla sought relief concerning his underlying conviction or the way his other state and federal cases had been handled.
Reasons for dismissal
The court addressed Bonilla’s possible requests to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without fees may do so only if the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger. He therefore could not proceed without paying the fees.
The court separately ruled that, even if an application to proceed without fees were granted, the lawsuits would be barred under the rules or doctrines identified in the order: 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 barriers.
The court also rejected any suggestion that the assigned judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and frivolous filings. The order noted that Bonilla named the judge as a defendant in one of the cases, but the visible text does not include the rest of that footnote.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. The court also noted Bonilla’s extensive history of filing similar cases, including the filing statistics stated in the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.