Bonilla v. 3rd Appellete District Court
- Phyllis Hamilton
- 4:25-cv-05905
- 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 filing restrictions and other legal bars applied.
Steven Wayne Bonilla's multiple nearly identical civil-rights lawsuits were dismissed with prejudice, and his pending motions and future filings in those closed cases were affected.
What happened
In Bonilla v. Sacramento County Superior Court, Steven Wayne Bonilla filed multiple nearly identical civil-rights lawsuits against judges, courts, and law-enforcement officials. He challenged his conviction and how other cases were handled.
Bonilla filed the lawsuits without a lawyer and sought to proceed without paying filing fees. The court said he had previously been barred from doing so unless he faced imminent danger of serious physical injury, which his allegations did not show.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, concluding that they also would be barred by several legal doctrines even if Bonilla could proceed without paying fees. The clerk was ordered to close the cases and return future filings without filing them.
The detailed version
- Bonilla v. 3rd Appellete District Court · No. 4:25-cv-05905
- 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 opinion lists numerous related case numbers, including 25-cv-5296-PJH, 25-cv-5351-PJH, 25-cv-5352-PJH, and others. The complaints presented nearly identical claims and 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 cases in state and federal court. The opinion states that he was a condemned prisoner with a pending federal habeas petition in the court, where he had appointed counsel. It also states that he was represented by counsel in state-court habeas proceedings.
Filing-fee restriction
The court explained that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute allows a disqualified prisoner to proceed without paying only if the complaint shows that the prisoner was under imminent danger of serious physical injury when the complaint was filed.
The court found that the allegations did not show imminent danger at the time of filing. Bonilla therefore could not proceed without paying the filing fee.
Other legal bars
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each doctrine in detail before entering its disposition.
The court also rejected the suggestion that the judge's impartiality could reasonably be questioned because of Bonilla's repetitive and allegedly frivolous filings. The opinion noted that Bonilla named the judge as a defendant in one of the cases but stated that he did not present a legitimate reason for the judge to recuse herself.
Disposition
The court dismissed the multiple cases with prejudice. It directed the clerk 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. The opinion notes that Bonilla had an extensive history of filing similar cases, including cases assigned to other judges and numerous orders concerning his filings.
The order was signed by United States District Judge Phyllis J. Hamilton on July 28, 2025.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.