Bonilla v. San Bernardino County Superior Court
4:25-cv-05249
| 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 currently represented by counsel in both federal and state habeas proceedings challenging his conviction.
- The complaints asserted nearly identical claims against federal and state courts, judges, clerks, and government agencies, seeking relief regarding his conviction and the handling of related cases.
- Bonilla sought to proceed in forma pauperis (IFP) despite having been previously barred from doing so under 28 U.S.C. § 1915(g) due to prior frivolous filings, unless under imminent danger.
- The court found no allegations of imminent danger and noted the extensive history of hundreds of other similar frivolous filings by Bonilla.
- The cases were dismissed with prejudice, and the court ordered that no further filings in these cases would be accepted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Qualification for IFP despite §1915(g) bar | Entitled to proceed IFP with civil rights claims | No imminent danger; §1915(g) applies | Not qualified for IFP |
| Claims regarding underlying conviction | Courts improperly handled his conviction/cases | Claims lack merit; barred by precedent | Dismissed |
| Suit against federal/state courts and agencies | Court actions violated rights | Claims are frivolous/duplicative | Dismissed |
| Judicial recusal due to being named defendant | Judge's impartiality might be questioned | No specific allegations; recusal unwarranted | No recusal |
Key Cases Cited
- Heck v. Humphrey, 512 U.S. 477 (claims challenging the validity of conviction or sentence are not cognizable under § 1983 unless conviction is invalidated)
- Younger v. Harris, 401 U.S. 37 (federal courts should not interfere with ongoing state prosecutions)
- Demos v. U.S. District Court, 925 F.2d 1160 (frivolous or repetitive habeas petitions may be dismissed without consideration)
- Mullis v. U.S. Bankruptcy Court, 828 F.2d 1385 (judicial immunity extends to judicial acts and precludes civil liability)
- United States v. Holland, 519 F.3d 909 (standard for recusal of district judges)