Bonilla v. Givens
- Phyllis Hamilton
- 4:25-cv-05603
- 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 was disqualified from proceeding without paying fees and other legal bars applied.
Steven Wayne Bonilla and the defendants in the multiple related cases were affected. The cases were dismissed with prejudice, closed, and stripped of any pending motions; future documents submitted in those cases were to be returned without filing.
What happened
In Steven Wayne Bonilla v. Sacramento County Superior Court et al., Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits under a federal law allowing claims against officials for rights violations. He sued various federal judges, state judges, state courts, and law-enforcement officials over his conviction and how his other cases were handled.
The court ruled that Bonilla could not proceed without paying filing fees because he was barred from that status unless he showed an immediate danger of serious physical injury, which his complaints did not show. The court also said that, even if he were allowed to proceed without paying fees, other legal rules barred the lawsuits. It dismissed the cases with prejudice, terminated the pending motions, closed the cases, and ordered the clerk to return future documents without filing them.
Judge Phyllis J. Hamilton also declined to step aside from the cases, stating that the repetitive and frivolous filings did not reasonably call her impartiality into question. The order was dated July 28, 2025.
The detailed version
- Bonilla v. Givens · No. 4:25-cv-05603
- Phyllis Hamilton
- July 28, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical complaints without a lawyer. The complaints asserted civil-rights claims under 42 U.S.C. § 1983, a federal statute that permits certain claims against officials for violating constitutional rights. The complaints named various federal judges, state judges, state courts, and law-enforcement officials as defendants. Bonilla sought relief concerning his underlying conviction and the handling of his other state and federal cases.
The order states that Bonilla was a condemned prisoner and had a pending federal petition challenging his custody in the same court with appointed counsel. It also states that he was represented by counsel in state proceedings concerning his custody. The court noted his history of filing similar cases.
Ruling
The court addressed Bonilla’s ability to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), the court stated that he had been disqualified from that status unless he was under imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger at the time of filing, so Bonilla could not proceed without paying the required fees.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The court therefore dismissed the cases with prejudice. The order does not set out a merits determination resolving whether Bonilla’s underlying allegations were legally correct.
Recusal and Case Closure
The court also considered whether Judge Hamilton’s impartiality might reasonably be questioned because of the repetitive and frivolous filings. It concluded that the cases did not present a reason for her to step aside. The order notes that Bonilla named Judge Hamilton as a defendant in one of the cases.
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 those closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.