Bonilla v. Second Appellate District Court
- Phyllis Hamilton
- 4:25-cv-05903
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Sacramento County Superior Court, Judge Hamilton dismissed multiple civil-rights lawsuits with prejudice because no imminent danger was shown and other legal bars applied.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice and closed; the named defendants were not required to litigate the claims on their merits.
What happened
In Bonilla v. Sacramento County Superior Court, Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights complaints without a lawyer. He sued various federal judges, state judges, courts, and law-enforcement officials, seeking relief related to his conviction and the handling of his other cases.
Bonilla was barred from proceeding without paying the filing fee unless he showed that he faced an immediate danger of serious physical injury when he filed. The court found that his complaints did not show such a danger. The court also said that, even if he could proceed without paying, the lawsuits were barred by other legal rules and prior decisions.
The court dismissed the cases with prejudice, ended all pending motions, and closed the cases. It also directed the clerk to return any further documents Bonilla submitted in those closed cases without filing them. Judge Phyllis J. Hamilton further concluded that the repetitive and allegedly frivolous filings did not provide a reasonable basis to question her impartiality.
The detailed version
- Bonilla v. Second Appellate District Court · No. 4:25-cv-05903
- Phyllis Hamilton
- July 28, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple nearly identical complaints under 42 U.S.C. § 1983, the federal civil-rights statute used to sue certain officials for constitutional violations. The complaints named various federal judges, state judges, state courts, and law-enforcement officials. Bonilla sought relief concerning his underlying conviction or the way his other state and federal cases had been handled.
The order notes that Bonilla had a pending federal petition challenging his custody in the same district, with appointed counsel, and was represented by counsel in state-court proceedings. The opinion also states that he had an extensive history of filing similar cases.
Filing-fee restriction and other barriers
The court addressed Bonilla's requests to proceed in forma pauperis, meaning without paying the filing fee. Under 28 U.S.C. § 1915(g), the court stated that Bonilla had been disqualified from proceeding without the fee unless he showed that he was in imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show imminent danger, so he could not proceed without paying the fee.
The court further stated that, even if an application to proceed without paying the fee were granted, the lawsuits would be barred under the authorities it cited: 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 validity of Bonilla's conviction or the merits of his specific civil-rights allegations.
Rulings and case status
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 those closed cases.
The order also addressed impartiality. Although Bonilla named Judge Hamilton as a defendant in one of the cases, the court concluded that the repetitive and frivolous nature of the filings did not create a situation in which the judge's impartiality could reasonably be questioned. Judge Hamilton signed the order on July 28, 2025.
Classification
This is a procedural order because the court disposed of the cases based on the filing-fee restriction and other threshold legal barriers without reaching the merits of the civil-rights claims.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.