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N.D. Cal.Procedural orderFiled July 28, 2025

Bonilla v. Chhabria

Judge
Phyllis Hamilton
Docket
4:25-cv-06144
Court
U.S. District Court · Northern District of California
Pages
3
Civil RightsSection 1983Pro SeCivil Procedure
In one sentence

In Bonilla v. Sacramento County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla did not show imminent danger and the suits were barred.

Who this affects

Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The named defendants and the clerk’s handling of future filings in those closed cases were also affected.

What happened

In Steven Wayne Bonilla v. Sacramento County Superior Court et. al., Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights complaints. He sued federal and state judges, courts, and law-enforcement officials over his conviction and the handling of his other cases.

The court ruled that Bonilla could not proceed without paying filing fees because he did not show that he faced an immediate danger of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without those fees, the lawsuits would be barred by several legal rules. It dismissed the cases with prejudice.

Judge Phyllis J. Hamilton also declined to recuse herself. The clerk was ordered to terminate all pending motions, close the cases, and return without filing any additional documents Bonilla submits in them.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Bonilla v. Chhabria · No. 4:25-cv-06144
Judge
Phyllis Hamilton
Date
July 28, 2025

Background

Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute. 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 and the way his other state and federal cases had been handled.

The opinion also states that Bonilla had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings.

Filing-fee status

The court stated that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed each complaint. The court found that the allegations did not show such danger. It therefore concluded that Bonilla could not proceed without paying the filing fee.

Other grounds for dismissal

The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not provide a separate claim-by-claim analysis of those rules.

Disposition

The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submits in the closed cases.

Recusal

The court rejected the suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of Bonilla’s filings. The opinion notes that Bonilla named Judge Hamilton as a defendant in one of the cases but does not provide additional analysis of that case in the text supplied.

The authoritative version

Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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