Bonilla v. Federal Bureau of Investigations
4:25-cv-04658
| N.D. Cal. | Jun 30, 2025Background
- Steven Wayne Bonilla, a state prisoner on death row, filed numerous pro se civil rights actions under 42 U.S.C. § 1983 in the Northern District of California.
- Bonilla has a pending federal habeas case (with appointed counsel) and is also represented in state habeas proceedings.
- The complaints are nearly identical, naming federal and state courts and agencies as defendants, seeking relief related to his conviction and other case dispositions.
- Bonilla has a longstanding history of submitting repetitious and frivolous filings in this court (over a thousand cases).
- He attempted to proceed in forma pauperis (IFP), but was previously barred from doing so under 28 U.S.C. § 1915(g), which only allows exceptions for imminent danger.
- The court consolidated dismissal of these cases with prejudice, also noting that recusal was unwarranted despite Bonilla naming the court as a defendant in some actions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| IFP eligibility under 28 U.S.C. § 1915(g) | Bonilla seeks to proceed despite the bar | Barred unless imminent danger shown | No imminent danger shown; IFP denied |
| Validity of civil rights claims against courts | Claims wrongful handling of his convictions | Courts/officials immune; claims not actionable | Claims barred under various doctrines |
| Bar under Heck v. Humphrey and related cases | Lawsuits not precluded by ongoing appeals | Claims would undermine conviction; precluded | Actions barred by precedent |
| Judicial recusal/partiality | Judge should recuse as a named defendant | No specific allegations; recusal unwarranted | No grounds for recusal |
Key Cases Cited
- Heck v. Humphrey, 512 U.S. 477 (claims that imply invalidity of conviction not actionable under § 1983 if conviction not reversed)
- Younger v. Harris, 401 U.S. 37 (federal courts must abstain from interfering with ongoing state proceedings)
- Demos v. U.S. District Court, 925 F.2d 1160 (overly repetitive/frivolous habeas applications barred)
- Mullis v. U.S. Bankruptcy Court, 828 F.2d 1385 (judicial immunity bars suits against judges for acts performed in their judicial capacity)
- United States v. Holland, 519 F.3d 909 (recusal not required absent legitimate basis; duty to sit in assigned cases)