Bonilla v. San Joaquin County Superior Court
4:25-cv-05248
| N.D. Cal. | Jun 30, 2025Background
- Steven Wayne Bonilla, a state prisoner on death row, filed multiple pro se civil rights lawsuits under 42 U.S.C. § 1983 in the Northern District of California.
- Bonilla simultaneously has active federal and state habeas corpus petitions, both with appointed counsel, addressing his underlying conviction.
- Each lawsuit Bonilla filed raised nearly identical claims, naming various federal and state courts and agencies as defendants, seeking relief related to his conviction or handling of his cases.
- Bonilla has a lengthy history of filing similar, repetitive, and frivolous lawsuits; the judge notes over 1,100 cases filed since 2011.
- Bonilla sought to proceed in forma pauperis (IFP) despite being disqualified absent a showing of imminent danger due to his history of abusive litigation.
- The court reviewed all applications and found no plausible claim of imminent danger, and held the lawsuits would be barred regardless on multiple legal grounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eligibility for IFP under § 1915(g) | Bonilla qualifies for IFP | Bonilla is disqualified; no danger | IFP denied; no imminent danger shown |
| Claims challenging conviction | Prior state/federal proceedings unfair | Courts acted lawfully | Barred by Heck v. Humphrey |
| Suits against judges and courts | Actions by courts violated rights | Suits are frivolous/immune | Barred by Demos, Mullis |
| Judicial impartiality/recusal | (Not expressly raised) | No reason for recusal | Recusal not warranted |
Key Cases Cited
- Heck v. Humphrey, 512 U.S. 477 (prohibits § 1983 claims that challenge the validity of a conviction unless the conviction has been overturned)
- Younger v. Harris, 401 U.S. 37 (federal courts generally must abstain from interfering in ongoing state proceedings)
- Demos v. U.S. District Court, 925 F.2d 1160 (federal courts may dismiss clearly baseless and repetitive suits)
- Mullis v. U.S. Bankruptcy Court, 828 F.2d 1385 (judicial officers are generally immune from suit for acts taken in a judicial capacity)
- United States v. Holland, 519 F.3d 909 (judge's duty to preside unless legitimate grounds for recusal exist)