Smith v. Keisel

United States District Court for the District of Utah · August 5, 2025 · No. 4:25-cv-00015

Summary

This memorandum decision and order from the United States District Court for the District of Utah denies a pro se prisoner plaintiff's motion for appointment of counsel. The court explains that civil litigants have no Sixth Amendment right to counsel and lacks authority to compel representation, though it may request volunteer attorneys under 28 U.S.C. § 1915(e)(1). After evaluating the merits, complexity, and plaintiff's ability to proceed, the court concludes the claims are not sufficiently colorable to warrant a request for pro bono assistance at this time.

Court
United States District Court for the District of Utah
Writing for the Court
Ann Marie McIff Allen
Jurisdiction
United States District Court for the District of Utah
Decision date
August 5, 2025
Docket number
4:25-cv-00015
Procedural posture
Motion for appointment of counsel denied
Precedential value
nonprecedential
Disposition
other

Topics

prisoners rightscivil rights

Practice areas

civil procedurecivil rights

Questions Presented

  1. Whether the district court may appoint counsel for a pro se civil litigant under 28 U.S.C. §1915(e)(1)
  2. Whether the plaintiff has a constitutional right to appointed counsel in a civil case

Holdings

  1. The court denied the motion for appointed counsel, finding that the plaintiff does not satisfy the statutory factors and has no Sixth Amendment right to counsel.

Key quotations

As a civil litigant, plaintiff has no Sixth Amendment right to counsel. (at 1)

Factual background

The plaintiff, a prisoner, filed a pro se civil‑rights suit and requested that the court appoint an attorney to represent him free of charge. The court noted that a civil litigant does not have a Sixth Amendment right to counsel and that the court’s authority to appoint counsel is limited to the statutory criteria in 28 U.S.C. §1915(e)(1).

Procedural history

Plaintiff, a pro se prisoner, filed a civil‑rights action and moved for appointment of counsel. The district court considered the motion under 28 U.S.C. §1915(e)(1) and denied it.

Court Document

Open PDF
Loading document…