Bonilla v. Plourd
- Phyllis Hamilton
- 4:25-cv-05598
- 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 the claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, and his pending motions were terminated. The named defendants were not required to litigate the claims further in these cases.
What happened
Steven Wayne Bonilla filed multiple nearly identical civil-rights cases against various federal judges, state judges, state courts, and law-enforcement officials. The cases challenged his conviction or how other state and federal cases had been handled.
Bonilla sought to proceed without paying filing fees, but the court said he was barred from doing so unless he showed an imminent danger of serious physical injury. The complaints did not make that showing. The court also said the lawsuits would be barred even if fee-waiver applications were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated the pending motions, and ordered the clerk to close the cases and return future filings without filing them. The court also declined to recuse Judge Hamilton based on the repetitive filings.
The detailed version
- Bonilla v. Plourd · No. 4:25-cv-05598
- Phyllis Hamilton
- July 28, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints were nearly identical. They named various federal judges, state judges, state courts, and law-enforcement officials as defendants and sought relief concerning Bonilla’s underlying conviction or the handling of his other state and federal cases.
The order states that Bonilla is a condemned prisoner with a pending federal petition challenging his custody in the same district, where he has appointed counsel. It also states that he is represented by counsel in state-court proceedings involving a similar petition.
Filing-fee status and claim barriers
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee 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 an imminent danger, so Bonilla could not proceed without paying the fees.
The court further stated that, even if an application to proceed without fees were granted, the lawsuits would be barred under the legal rules 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 decide the underlying legal questions concerning Bonilla’s conviction or the handling of his other cases.
Recusal
The court rejected the suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. Citing a Ninth Circuit decision, the court stated that, absent legitimate grounds for recusal, a judge has a duty to hear assigned cases. The order also noted Bonilla’s extensive history of filing similar cases.
Disposition
The court 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.