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Bonilla v. Alpine County Superior Court
4:25-cv-05255
| N.D. Cal. | Jun 30, 2025
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Background

  • 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)
Read the full case

Case Details

Case Name: Bonilla v. Alpine County Superior Court
Court Name: District Court, N.D. California
Date Published: Jun 30, 2025
Docket Number: 4:25-cv-05255
Court Abbreviation: N.D. Cal.