Bonilla v. Alpine County Superior Court
4:25-cv-05255
| N.D. Cal. | Jun 30, 2025Background
- Steven Wayne Bonilla, a state prisoner on death row, filed numerous pro se civil rights lawsuits under 42 U.S.C. § 1983 in the Northern District of California.
- Bonilla is concurrently represented by counsel in pending federal and state habeas actions concerning his conviction.
- The complaints repeatedly target state and federal courts and agencies, alleging improper handling of his conviction or other cases.
- Bonilla moved to proceed in forma pauperis (IFP) but has been barred from doing so under 28 U.S.C. § 1915(g) due to prior frivolous filings, absent imminent danger.
- The court reviewed multiple nearly identical complaints, all lacking allegations of imminent physical danger.
- The presiding judge has handled hundreds of similar filings and noted an extensive history of vexatious litigation by Bonilla.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eligibility for IFP under § 1915(g) | Bonilla should proceed IFP | Plaintiff is barred; no imminent danger shown | IFP denied |
| Claims challenging underlying conviction | Conviction and court actions were improper | Claims not cognizable under § 1983 (Heck) | Claims barred by Heck; dismissed |
| Frivolous/repetitive litigation | Bonilla has legitimate grievances | Prior history of meritless, repetitive cases | Dismissed with prejudice |
| Judicial impartiality/recusal | N/A (Bonilla did not request recusal) | No recusal warranted despite being named as party | No recusal; judge sits in judgment |
Key Cases Cited
- Heck v. Humphrey, 512 U.S. 477 (claims attacking conviction not cognizable under § 1983 unless conviction is invalidated)
- Younger v. Harris, 401 U.S. 37 (federal courts must refrain from interfering in ongoing state proceedings)
- Demos v. U.S. District Court, 925 F.2d 1160 (repetitive habeas petitions may be dismissed as frivolous)
- Mullis v. U.S. Bankruptcy Court, 828 F.2d 1385 (court and court staff immune from § 1983 suits for judicial acts)
- United States v. Holland, 519 F.3d 909 (duty of judge to sit unless recusal is warranted)
