Bonilla v. White
4:24-cv-09272
| N.D. Cal. | Jan 6, 2025Background
- Steven Wayne Bonilla, a state prisoner and condemned inmate, filed numerous pro se civil rights complaints under 42 U.S.C. § 1983 in federal court.
- Bonilla has pending federal and state habeas petitions for which he is represented by counsel.
- The complaints largely duplicate each other, naming various federal and state judges and officials and challenging his conviction and court case handling.
- Bonilla is barred from proceeding in forma pauperis under 28 U.S.C. § 1915(g) unless he is in imminent danger, which the court found he is not.
- The court noted Bonilla’s extensive history of filing hundreds of nearly identical or frivolous lawsuits in the district.
- The court considered and denied the need for judicial recusal, despite Bonilla naming the judge as a defendant in some filings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eligibility for in forma pauperis (IFP) | Entitled to IFP status | Barred by § 1915(g) without danger | Not eligible; no imminent danger shown |
| Sufficiency of claims under § 1983 | Challenges to conviction and court actions | Frivolous/repetitive, not proper | Claims barred; dismissed with prejudice |
| Application of Heck/Younger/Demos/Mullis doctrines | Proper claims under civil rights law | Barred by precedent | Barred under cited precedents |
| Judicial recusal | Judge named as defendant | No grounds for recusal | No recusal; cases too frivolous |
Key Cases Cited
- Heck v. Humphrey, 512 U.S. 477 (claims relating to unlawful conviction or imprisonment must be dismissed if a judgment in the plaintiff’s favor would necessarily imply the invalidity of his conviction)
- Younger v. Harris, 401 U.S. 37 (federal courts must abstain from interfering with ongoing state proceedings)
- Demos v. U.S. Dist. Court, 925 F.2d 1160 (federal courts may summarily dismiss repetitive, frivolous actions)
- Mullis v. U.S. Bankruptcy Court, 828 F.2d 1385 (judicial immunity protects judges from suit based on judicial actions)
- United States v. Holland, 519 F.3d 909 (recusal only warranted for legitimate reasons; judges have a duty to sit on assigned cases)