Bonilla v. Jackson
4:24-cv-08848
| N.D. Cal. | Dec 16, 2024Background:
- Steven Wayne Bonilla, a state prisoner, filed numerous pro se civil rights complaints under 42 U.S.C. § 1983 in the Northern District of California.
- Bonilla is a condemned prisoner with pending federal and state habeas proceedings, where he is represented by counsel.
- The complaints name various federal and state judges and officials, mainly challenging his conviction and the handling of his previous cases.
- Bonilla attempted to file these cases in forma pauperis (IFP), but he has been disqualified from IFP status under 28 U.S.C. § 1915(g) due to previous frivolous filings unless he shows imminent danger, which he did not.
- The court noted that, even if IFP was granted, the cases would be barred on various grounds, including bars from Heck v. Humphrey and Younger v. Harris.
- The court dismissed all cases with prejudice, citing Bonilla’s extensive history of frivolous litigation and confirming no basis for recusal, despite Bonilla naming the judge as a defendant in one action.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eligibility for IFP Status | Bonilla should proceed IFP to litigate his claims | Bonilla is barred by § 1915(g) absent imminent danger | Bonilla is not eligible for IFP; no imminent danger shown |
| Validity of Claims Challenging Conviction | Conviction and case handling violated rights | Claims are improper due to prior bars and ongoing proceedings | Claims barred under precedents Heck, Younger, and others |
| Frivolous/Frequent Litigant Status | N/A | Bonilla is a frequent frivolous filer | Court affirms history and dismisses with prejudice |
| Judicial Recusal | Judge should recuse due to being named as a defendant | No valid grounds for recusal given the nature of the filings | No recusal; judge remains impartial |
Key Cases Cited
- Heck v. Humphrey, 512 U.S. 477 (bars § 1983 claims that would necessarily imply the invalidity of a conviction)
- Younger v. Harris, 401 U.S. 37 (federal courts must abstain from interfering with ongoing state criminal proceedings)
- Demos v. U.S. District Court, 925 F.2d 1160 (upholds dismissal of habeas-like claims filed under § 1983)
- Mullis v. U.S. Bankruptcy Court, 828 F.2d 1385 (discusses immunity of judges from damages when acting in their judicial capacity)