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Bonilla v. U.S. District Court San Francisco
4:24-cv-07972
| N.D. Cal. | Dec 16, 2024
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Background

  • 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)
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Case Details

Case Name: Bonilla v. U.S. District Court San Francisco
Court Name: District Court, N.D. California
Date Published: Dec 16, 2024
Docket Number: 4:24-cv-07972
Court Abbreviation: N.D. Cal.