Bonilla v. Siskiyou County Superior Court
- Phyllis Hamilton
- 4:25-cv-05916
- U.S. District Court · Northern District of California
- 3
Bonilla v. Sacramento County Superior Court: Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and several legal bars.
Steven Wayne Bonilla’s multiple pro se civil-rights cases were dismissed with prejudice. The defendants and Bonilla’s pending motions were affected, and the cases were closed.
What happened
In Bonilla v. Sacramento County Superior Court, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed many nearly identical civil-rights cases against various federal judges, state judges, courts, and law-enforcement officials. He challenged his conviction and how other cases had been handled.
The court found that Bonilla could not proceed without paying the filing fees because his allegations did not show that he faced imminent danger of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without paying, the lawsuits were barred by several legal rules. It dismissed the cases with prejudice, terminated pending motions, closed the cases, and directed the clerk to return future filings without filing them.
Judge Phyllis J. Hamilton also rejected the suggestion that her impartiality could reasonably be questioned because of Bonilla’s repeated filings. The court noted his history of similar cases and entered the dismissal order on July 28, 2025.
The detailed version
- Bonilla v. Siskiyou County Superior Court · No. 4:25-cv-05916
- 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 allowing certain civil-rights claims against state actors. The complaints were nearly identical. They named various federal judges, state judges, state courts, and law-enforcement officials as defendants. The opinion says Bonilla sought relief concerning his underlying conviction and the handling of his other state and federal cases.
Bonilla had a pending federal habeas petition in the same court with appointed counsel and was represented by counsel in state habeas proceedings. The opinion also states that he had an extensive history of filing similar cases.
Rulings
The court addressed Bonilla’s requests to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally cannot proceed without paying unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that the complaints did not show such danger, so Bonilla could not proceed without paying the fees.
The court further stated that, even if a request to proceed without paying fees were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion does not explain which specific bar applied to which case or claim. The court therefore dismissed the cases with prejudice. It directed the clerk to terminate all pending motions, close the cases, and return without filing any additional documents Bonilla submitted in the closed cases.
Recusal issue and disposition
Bonilla named Judge Hamilton as a defendant in one of the cases. The court nevertheless concluded that its impartiality could not reasonably be questioned merely because of the repetitive and frivolous nature of the filings. Judge Hamilton entered the order dismissing all of the listed cases with prejudice and closing them.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.