Bonilla v. Pettit
- Phyllis Hamilton
- 4:25-cv-06051
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Sacramento County Superior Court, Judge Hamilton dismissed the civil-rights 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 and closed. The order also terminated pending motions and directed the clerk to return future documents submitted in those closed cases without filing them.
What happened
In Bonilla v. Sacramento County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed many nearly identical civil-rights lawsuits against judges, courts, and law-enforcement officials. He challenged his conviction and how other state and federal cases had been handled.
The court found that Bonilla could not proceed without paying the filing fees because he had previously been barred from using that option and had not shown an immediate risk of serious physical injury when he filed. The court also said that, even if he had been allowed to proceed without fees, the lawsuits would be barred by several legal rules, including rules concerning challenges to convictions and interference with ongoing proceedings.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that further documents submitted in the closed cases be returned without filing.
The detailed version
- Bonilla v. Pettit · No. 4:25-cv-06051
- 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 states that he is a condemned prisoner with a pending federal petition challenging his custody, for which he has appointed counsel, and that he is represented by counsel in state-court proceedings. The complaints were nearly identical and named various federal judges, state judges, state courts, and law-enforcement officials. They sought relief concerning Bonilla's underlying conviction or the handling of his other cases.
Reasons for dismissal
The court stated that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he showed that he faced an imminent danger of serious physical injury when he filed. The court found that his allegations did not show such a danger. It therefore concluded that he could not proceed without paying the fees.
The court further stated that, even if Bonilla had been allowed to proceed without paying fees, the lawsuits would be barred under several legal doctrines and precedents: Heck v. Humphrey, concerning civil claims that would undermine a conviction or sentence; Younger v. Harris, concerning federal interference with certain ongoing proceedings; Demos v. U.S. District Court; and 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 assigned judge's impartiality could reasonably be questioned because of the repetitive and frivolous filings, noting that Bonilla had named the judge as a defendant in one of the cases but, according to the opinion, had not presented a legitimate reason for recusal.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. The opinion does not describe a merits determination of the underlying civil-rights allegations; the dismissal rested on the filing-fee restriction and the stated legal bars.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.