Bonilla v. USDC CAND SF Judges and Court Clerks
4:25-cv-04527
| 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.
- Bonilla is already represented by counsel in both federal and state habeas proceedings related to his conviction.
- The complaints named numerous federal and state judicial and governmental parties, repeating nearly identical claims across multiple cases.
- Bonilla sought relief concerning the circumstances of his conviction and the management of his other court cases.
- The court recognized Bonilla's extensive history of filing similar lawsuits, many deemed frivolous.
- These cases were assigned to Judge Phyllis J. Hamilton, the fourth judge to handle Bonilla’s filings, and concern a large volume of dismissals over several years.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eligibility to Proceed In Forma Pauperis | Entitled to IFP due to indigence | Disqualified under § 1915(g) due to prior frivolous filings; not in danger | Ineligible for IFP; not in imminent danger |
| Validity of Complaints under § 1983 | Alleges rights violations from conviction or court actions | Complaints seek improper relief not available under § 1983, barred by precedents | Dismissed as barred by established case law |
| Judicial Impartiality and Recusal | No specific allegations; did not seek recusal | Court’s impartiality not reasonably called into question | Recusal not warranted |
| Permissibility of Repeated Filings | Presenting new grievances arising from conviction | Repetitive, frivolous, and previously addressed claims | Dismissed with prejudice |
Key Cases Cited
- Heck v. Humphrey, 512 U.S. 477 (Claims seeking to challenge conviction are not actionable under § 1983 unless conviction is overturned)
- Younger v. Harris, 401 U.S. 37 (Federal courts should not interfere with ongoing state criminal proceedings)
- Demos v. U.S. District Court, 925 F.2d 1160 (Ninth Circuit rejects repeated, frivolous habeas filings under § 1983)
- Mullis v. U.S. Bankruptcy Court, 828 F.2d 1385 (Judicial officers are generally immune for actions taken in their judicial capacity)