Bonilla v. Nevada County Superior Court
- Phyllis Hamilton
- 4:25-cv-05912
- 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 they were barred by filing restrictions and other legal rules.
Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice; the clerk was directed to close them and return later submissions without filing them.
What happened
In Bonilla v. Sacramento County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed many similar civil-rights lawsuits against judges, courts, and law-enforcement officials. He sought relief connected to his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fee because he had previously been barred from proceeding without fees and had not shown an immediate danger of serious physical injury when he filed. The court also said the lawsuits would be barred for other reasons even if he were allowed to proceed without paying.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return future documents submitted in them without filing them.
The detailed version
- Bonilla v. Nevada County Superior Court · No. 4:25-cv-05912
- Phyllis Hamilton
- July 28, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal law that allows certain civil-rights claims against state officials. The complaints presented nearly identical claims and named various federal judges, state judges, state courts, and law-enforcement officials. Bonilla sought relief concerning his underlying conviction and the handling of his other cases by state and federal courts.
The opinion states that Bonilla had a pending federal petition challenging his imprisonment in the same district, with appointed counsel, and was also represented by counsel in state court proceedings. The court also noted his extensive history of filing similar cases.
Reasons for dismissal
The court addressed Bonilla’s attempt to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally may not proceed without paying unless the complaint shows that the prisoner faced an immediate danger of serious physical injury when the complaint was filed. The court said Bonilla had been disqualified from proceeding without fees and that his allegations did not show such an immediate danger.
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 Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each complaint or explain which particular rule applied to each case.
Ruling
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.
The court additionally rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The opinion states that Bonilla named the judge as a defendant in one of the cases, but the excerpt provided ends before the rest of that footnote is available.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.