Bonilla v. U.S. District Court San Francisco
4:24-cv-07972
| N.D. Cal. | Dec 16, 2024Background
- Steven Wayne Bonilla, a state prisoner, filed multiple pro se civil rights complaints under 42 U.S.C. § 1983 in the Northern District of California.
- Bonilla is a condemned prisoner who already has pending federal and state habeas petitions, both with appointed counsel.
- His complaints presented nearly identical claims targeting federal and state judges and officials regarding his conviction and prior case handling.
- Bonilla has previously been barred from proceeding in forma pauperis (IFP) under 28 U.S.C. § 1915(g) due to filing three or more prior cases deemed frivolous or malicious.
- The court identified a pattern of repetitive and frivolous filings by Bonilla and dismissed these latest cases with prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eligibility to proceed IFP under § 1915(g) | Bonilla should be allowed to proceed IFP | Barred as vexatious litigant, not in danger | Not eligible; no imminent harm alleged |
| Claims regarding conviction and case handling | Relief regarding conviction and past case adjudication | Courts and officials immune; improper claims | Claims barred; dismissed with prejudice |
| Judge's impartiality/recusal | (Named judge as defendant, but no recusal requested) | No grounds for recusal; frivolous filings | Recusal not warranted; judge presides |
| Repetitive/frivolous litigation | (Did not address pattern of filings) | Pattern of abuse, many frivolous cases filed | Cases dismissed as frivolous and abusive |
Key Cases Cited
- Heck v. Humphrey, 512 U.S. 477 (claim challenging legality of conviction not cognizable under § 1983 unless conviction is invalidated)
- 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 (denying repetitive, frivolous federal filings by prisoners)
- Mullis v. U.S. Bankruptcy Court, 828 F.2d 1385 (judicial immunity protects judges from suit on basis of judicial acts)
