Summary
The United States District Court for the Northern District of Ohio denied pro se plaintiff Cristin D. Taylor, Sr.’s motion for appointment of counsel in his 42 U.S.C. § 1983 action against the Akron Police Department and related defendants. The court held that Taylor had not demonstrated the exceptional circumstances required for appointed counsel because the claims were not unusually complex and his lack of legal training and financial hardship were insufficient.
Holdings
- A civil litigant has no constitutional right to appointed counsel, and appointment under 28 U.S.C. § 1915(e) is warranted only in exceptional circumstances. Taylor's lack of legal training, indigence, and generalized assertions about the difficulty of proceeding pro se did not establish exceptional circumstances, so the motion for appointment of counsel was denied.
Questions Presented
- Whether exceptional circumstances justified appointing counsel for the pro se plaintiff in this civil § 1983 action.
Disposition
other
Cases Cited (10)
- Lavado v. Keohane, 992 F.2d 601, 605-06 (6th Cir. 1993)(followed)
- Lanier v. Bryant, 332 F.3d 999, 1006 (6th Cir. 2003)(followed)
- Redd v. Conway, 160 F. App'x 858, 863 (11th Cir. 2005)(followed)
- Buchanan v. Lee, 618 F. Supp. 3d 707, 712 (M.D. Tenn. 2022)(followed)
- Mackey v. DiCaprio, 312 F. Supp. 2d 580, 582 (S.D.N.Y. 2004)(followed)
- Hymas v. United States Dep't of State, No. 3:23-cv-336, 2025 WL 1136067, at *3 (E.D. Tenn. Apr. 17, 2025)(followed)
- Edwards v. Simpson, 833 F.2d 1012 (6th Cir. 1987)(followed)
- Brubaker v. Barrett, 801 F. Supp. 2d 743, 763 (E.D. Tenn. 2011)(followed)
- Horacek v. Carter, No. 1:20-cv-11682, 2022 WL 21841898, at *2 (E.D. Mich. July 15, 2022)(followed)
- Cavin v. Michigan Department of Corrections, Cavin v. Michigan Dep't of Corr., 927 F.3d 455, 461 (6th Cir. 2019)(followed)
Cited In (0)
No citing cases on record yet.
Court Document
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