Collins v. Repp

United States District Court, District of Nevada · January 28, 2025 · No. 2:24-cv-00676

Summary

This United States District Court for the District of Nevada order denies Plaintiff Ambibe Collins’s motion to appoint counsel. The Court explains that indigent litigants do not have a constitutional right to counsel in civil cases and that judicial request for counsel requires "exceptional circumstances," which are not established merely by an inability to afford counsel. After reviewing the docket, the Court found no exceptional circumstances based on the complexity of the claims, likelihood of success, or Plaintiff's demonstrated ability to proceed pro se.

Court
United States District Court, District of Nevada
Writing for the Court
Nancy J. Koppe
Jurisdiction
United States District Court, District of Nevada
Decision date
January 28, 2025
Docket number
2:24-cv-00676
Procedural posture
motion to appoint counsel
Precedential value
nonprecedential
Disposition
disapproved

Topics

civil procedurecivil rights

Practice areas

civil procedurecivil rights

Questions Presented

  1. Whether a civil‑rights plaintiff who cannot afford counsel is entitled to court‑appointed counsel under 28 U.S.C. §1915(e)(1).
  2. Whether the plaintiff demonstrated the "exceptional circumstances" required for appointment of counsel.

Holdings

  1. The motion to appoint counsel is denied because inability to afford counsel alone does not satisfy the statutory requirement of "exceptional circumstances".

Key quotations

The court may request an attorney to represent any person unable to afford counsel.
Neither of these considerations is dispositive and instead must be viewed together.

Factual background

Plaintiff Ambibe Collins alleges he cannot afford counsel to pursue a colorable civil‑rights claim. He has not demonstrated exceptional circumstances, nor a likelihood of success on the merits.

Procedural history

Plaintiff filed a motion (Docket No. 15) seeking court‑appointed counsel for a civil‑rights claim. The district court considered the motion and denied it.

Court Document

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