West v. Phelan

West v. Phelan · United States District Court for the Southern District of Indiana · February 24, 2026 · No. 3:25-cv-00199-RLY-CSW

Summary

The United States District Court for the Southern District of Indiana denied Iona West’s motion for appointment of counsel. The court concluded that West had paid the filing fee, had not established indigence, had not demonstrated sufficiently extensive efforts to obtain counsel, and had not shown an inability to litigate the case pro se.

Holdings

  1. Civil case litigants in federal court have no general right to appointed counsel.
  2. The plaintiff did not establish grounds for recruited counsel because she did not demonstrate that she was indigent, had made reasonable efforts to obtain counsel, or was unable to litigate the matter herself.

Questions Presented

  1. Whether the plaintiff was entitled to appointment or recruitment of counsel in her civil action.
  2. Whether the plaintiff satisfied the requirements for recruited counsel by demonstrating indigency, reasonable efforts to obtain counsel, and an inability to litigate the case herself.

Disposition

other

Cases Cited (2)

  • Walker v. Price, 900 F.3d 993, 938 (7th Cir. 2018)(followed)
  • Pruitt v. Mote, 503 F.3d 647, 654 (7th Cir. 2007) (en banc)(followed)

Cited In (0)

No citing cases on record yet.

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