Bonilla v. Amador County Superior Court
4:25-cv-05198
| N.D. Cal. | Jun 30, 2025Background
- Steven Wayne Bonilla, a state prisoner on death row, filed multiple pro se civil rights complaints under 42 U.S.C. § 1983 in the Northern District of California.
- Bonilla is already represented by counsel for his federal and state habeas proceedings.
- The complaints presented nearly identical claims, naming various federal and state courts and agencies as defendants, and sought relief related to Bonilla’s underlying conviction or the handling of his other cases.
- Bonilla has a lengthy history of filing hundreds of similar, frivolous lawsuits in this district.
- Bonilla was previously disqualified from proceeding in forma pauperis under 28 U.S.C. § 1915(g) due to prior abusive litigation, unless facing "imminent danger of serious physical injury."
- The current complaints did not allege such imminent danger, and the court also found his claims otherwise barred and frivolous.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Can Bonilla proceed IFP under §1915(g) for these cases? | Entitled to file as IFP | Barred due to prior abusive litigation | Not allowed; no showing of imminent danger |
| Are Bonilla's claims cognizable under § 1983? | Conviction and court proceedings at issue | Claims are attacks on conviction | Barred by Heck, Younger, and precedents |
| Should the court recuse due to being named as defendant? | Judge’s impartiality could be questioned | No legitimate recusal grounds | No grounds for recusal; impartiality not in doubt |
| Can Bonilla continue submitting documents in closed cases? | Entitled to pursue claims | Submissions should be barred | Terminated; new filings returned without docketing |
Key Cases Cited
- Heck v. Humphrey, 512 U.S. 477 (claims challenging validity of conviction not cognizable under § 1983 unless conviction reversed)
- Younger v. Harris, 401 U.S. 37 (federal courts should not interfere with ongoing state court proceedings)
- Demos v. U.S. District Court, 925 F.2d 1160 (declining habeas relief not available under § 1983 for claims cognizable in habeas)
- Mullis v. U.S. Bankruptcy Court, 828 F.2d 1385 (judicial immunity and improper § 1983 claims against courts/judges)
- United States v. Holland, 519 F.3d 909 (standards for judicial recusal)