Bonilla v. Stanislas County Superior Court
- Phyllis Hamilton
- 4:25-cv-05918
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Sacramento County Superior Court, Judge Hamilton dismissed multiple cases with prejudice because Bonilla could not proceed without fees and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The defendants named in those cases were affected by the closures, and the clerk was directed to terminate pending motions and return future submissions without filing them.
What happened
In Bonilla v. Sacramento County Superior Court, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights cases without a lawyer. He sued federal and state judges, courts, and law-enforcement officials over his conviction and the handling of other cases.
The court said Bonilla could not proceed without paying filing fees because he did not show that he faced an immediate risk of serious physical injury when he filed. The court also said that, even if he could proceed without fees, legal rules would bar the lawsuits. It dismissed the cases with prejudice, meaning the order bars refiling these cases.
Judge Phyllis J. Hamilton also declined to treat the repetitive filings as a reason to question her impartiality. She directed the clerk to terminate all pending motions, close the cases, and return any further documents Bonilla submits in them without filing them.
The detailed version
- Bonilla v. Stanislas County Superior Court · No. 4:25-cv-05918
- Phyllis Hamilton
- July 28, 2025
Background
Steven Wayne Bonilla, described as a state prisoner and a condemned prisoner, filed multiple pro se civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical. They named various federal judges, state judges, state courts, and law-enforcement officials as defendants and sought relief concerning Bonilla’s underlying conviction or the way his state and federal cases had been handled.
The opinion states that Bonilla had a pending federal petition challenging his confinement in the same district, with appointed counsel, and was also represented by counsel in state-court proceedings. The court further noted Bonilla’s extensive history of filing similar cases.
Court’s Ruling
The court held that Bonilla was disqualified from proceeding in these cases without paying the filing fees under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger.
The court also stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The court therefore dismissed the cases with prejudice. The opinion also states that the filings did not create a reasonable question about Judge Phyllis J. Hamilton’s impartiality based solely on their repetitive and frivolous nature.
The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submits in the closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.