Brandon Miguel Escamilla v. A. Oboyle, et al.

Summary

The United States District Court for the Eastern District of California denied Brandon Miguel Escamilla’s renewed request for appointment of counsel in his prisoner civil rights action. The court held that his mental health condition, administrative segregation, and potential loss of inmate assistance did not establish the exceptional circumstances required for voluntary appointment of counsel under 28 U.S.C. § 1915(e)(1).

Holdings

1. A district court may request voluntary assistance of counsel under 28 U.S.C. § 1915(e)(1) only when exceptional circumstances are shown; plaintiff did not demonstrate such circumstances.
2. Worsening mental health supported by records, administrative segregation, difficulty obtaining evidence, and anticipated loss of inmate assistance did not establish exceptional circumstances because plaintiff remained able to articulate his claims and had no pending deadlines.

Questions Presented

1. Whether plaintiff demonstrated exceptional circumstances warranting the court's request for voluntary appointment of counsel under 28 U.S.C. § 1915(e)(1).
2. Whether plaintiff's mental-health condition, administrative-segregation housing, difficulties investigating the case, and loss of assistance from another inmate established an inability to litigate pro se.

Disposition

other