Wright v. Garrigan

Summary

The United States District Court for the Northern District of California denied William L. Wright’s request for reconsideration of the dismissal with prejudice of his Eighth Amendment medical-care action against prison and hospital physicians. The court held that Wright showed no newly discovered evidence, clear error, manifest injustice, or intervening change in controlling law, and that neither reliance on a jailhouse lawyer nor the absence of court-appointed counsel warranted relief. The denial was without prejudice to filing a renewed reconsideration motion accompanied by a proposed second amended complaint.

Holdings

1. Reconsideration was not warranted because Wright identified no newly discovered evidence, clear error, manifest injustice, or intervening change in controlling law supporting vacatur of the dismissal.
2. The Court was not required to appoint counsel sua sponte because Wright did not demonstrate exceptional circumstances warranting appointment of counsel in this civil action.
3. Reliance on a jailhouse lawyer did not make the dismissal with prejudice unjust or excuse the deficient pleadings.

Questions Presented

1. Whether Wright established grounds for reconsideration of the dismissal with prejudice based on newly discovered evidence, clear error, manifest injustice, or an intervening change in controlling law.
2. Whether the Court was required to appoint counsel sua sponte at the pleading stage because Wright's medical-treatment claims presented exceptional circumstances.
3. Whether reliance on a jailhouse lawyer rendered the dismissal with prejudice unjust.

Disposition

other