Bonilla v. Mono County Superior Court
- Phyllis Hamilton
- 4:25-cv-05910
- 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 paying and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the order also terminated pending motions and closed those cases.
What happened
In Steven Wayne Bonilla v. Sacramento County Superior Court et al., Bonilla, a state prisoner representing himself, filed many nearly identical civil-rights cases against judges, courts, and law-enforcement officials. He sought relief related to his conviction and how other cases had been handled.
The court said Bonilla had been barred from proceeding without paying the filing fees unless he showed an immediate risk of serious physical injury when he filed. The complaints did not show that risk. The court also said the lawsuits would be barred under several legal rules even if permission to proceed without paying were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was ordered to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Mono County Superior Court · No. 4:25-cv-05910
- Phyllis Hamilton
- July 28, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute used to sue state actors for certain constitutional violations. The opinion identifies Bonilla as a condemned prisoner who has a pending federal habeas petition in the same court with appointed counsel and is represented by counsel in state-court habeas proceedings.
The complaints were nearly identical. They named various federal judges, state judges, state courts, and law-enforcement officials as defendants. Bonilla sought relief concerning his underlying conviction or the handling of his other cases by state and federal courts.
Court’s analysis
The court addressed Bonilla’s ability to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without paying may do so only if the complaint shows that the prisoner was facing an imminent danger of serious physical injury when the complaint was filed. The court concluded that these complaints did not show such imminent danger.
The court further stated that, even if Bonilla’s applications to proceed without paying were granted, the lawsuits would be barred under the rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion also noted Bonilla’s extensive history of filing similar cases.
The court rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. It cited the rule that, absent legitimate grounds for recusal, a judge has a duty to decide cases assigned to that judge. The opinion notes that Bonilla named Judge Hamilton as a defendant in one of the cases, but the provided text cuts off before giving additional details in footnote 2.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases, and 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.