Bonilla v. Kochler
- Phyllis Hamilton
- 4:25-cv-05602
- U.S. District Court · Northern District of California
- 3
Bonilla v. Sacramento County Superior Court: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and the suits were barred.
Steven Wayne Bonilla’s multiple civil-rights cases against the defendants named in those cases were dismissed with prejudice, and the cases were closed.
What happened
In Bonilla v. Sacramento County Superior Court et al., Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights lawsuits without a lawyer against judges, courts, and law-enforcement officials. He sought relief related to his conviction and the handling of other cases.
The court said Bonilla could not proceed without paying filing fees because he had been barred from using the fee-waiver process unless he showed an immediate risk of serious physical injury. The complaints did not show that risk. The court also said the lawsuits would be barred for additional legal reasons even if fee waivers were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and ordered the clerk to close the cases and return future filings in them without filing them. The court also rejected any concern that the judge’s impartiality could reasonably be questioned because of the repetitive filings.
The detailed version
- Bonilla v. Kochler · No. 4:25-cv-05602
- Phyllis Hamilton
- July 28, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple similar complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute that allows claims against state actors for violating federal rights. The defendants included various federal judges, state judges, state courts, and law-enforcement officials. The complaints sought relief concerning Bonilla’s underlying conviction or the handling of his other state and federal cases.
The opinion states that Bonilla is a condemned prisoner with a pending federal petition challenging his custody in the same court, where he has appointed counsel. It also states that he is represented by counsel in state-court proceedings.
Reasons for dismissal
The court addressed Bonilla’s possible requests to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the relevant prior dismissals generally may not proceed without paying the filing fee unless the complaint shows that the prisoner faced an immediate danger of serious physical injury when the complaint was filed. The court found that these complaints did not show such a 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 discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis of those barriers.
Ruling and case status
The court dismissed the cases with prejudice. It also concluded that the repetitive and allegedly frivolous nature of the filings did not create a reasonable basis to question the undersigned judge’s impartiality. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
The opinion notes that it was the 77th order issued by Judge Hamilton since April 30, 2020, concerning 1,162 different cases filed by Bonilla, and that Bonilla had filed 962 other cases with three other judges since 2011.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.