Bonilla v. United States Attorney General's Office - San Franscisco
4:25-cv-04711
| 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 already represented by appointed counsel in ongoing federal and state habeas proceedings concerning his conviction.
- The complaints brought nearly identical claims, naming as defendants various state and federal courts and agencies, seeking relief concerning his conviction or the handling of other cases.
- Bonilla attempted to proceed in forma pauperis (IFP), but is subject to a 28 U.S.C. § 1915(g) bar due to previous filings unless showing imminent danger, which he failed to allege.
- Even if IFP status were granted, the suits would be barred by several judicial doctrines, including those prohibiting challenges to convictions in civil rights lawsuits and abstaining from interfering with ongoing state matters.
- Bonilla has a history of prolific, repetitive, and frivolous filings, leading to repeated dismissals by multiple judges within the district.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eligibility for IFP under § 1915(g) | Bonilla seeks to proceed IFP despite litigation restrictions | Bonilla is barred absent imminent danger | Plaintiff not eligible to proceed IFP |
| Validity of § 1983 claims on conviction | Bonilla raises civil rights claims implicating his underlying conviction | Claims barred by Heck and similar doctrines | Claims not permitted under civil rights law |
| Recusal of presiding judge | (Bonilla did not seek recusal but named court as defendant) | No basis for recusal | No recusal warranted due to frivolous/repetitive nature |
| Dismissal with prejudice | Bonilla seeks relief concerning conviction and proceeding handling | Prior extensive frivolous litigation history | Cases dismissed with prejudice due to frivolous claims |
Key Cases Cited
- Heck v. Humphrey, 512 U.S. 477 (1994) (bar on § 1983 claims challenging the lawfulness of a conviction)
- Younger v. Harris, 401 U.S. 37 (1971) (federal courts abstain from interfering with ongoing state criminal proceedings)
- Demos v. U.S. District Court, 925 F.2d 1160 (9th Cir. 1991) (repetitive and frivolous filings by prisoner barred)
- Mullis v. U.S. Bankruptcy Court, 828 F.2d 1385 (9th Cir. 1987) (judicial immunity bars suits against courts and judges)
- United States v. Holland, 519 F.3d 909 (9th Cir. 2008) (standard for recusal due to impartiality concerns)