Alexander v. Tisdale

CourtDistrict Court, S.D. Georgia
DecidedApril 30, 2025
Docket4:25-cv-00093
StatusUnknown

This text of Alexander v. Tisdale (Alexander v. Tisdale) is published on Counsel Stack Legal Research, covering District Court, S.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alexander v. Tisdale, (S.D. Ga. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF GEORGIA SAVANNAH DIVISION

LETTERIOUS ALEXANDER, ) ) Plaintiff, ) ) v. ) CV425-015 ) AARON PINEIRO, et al., ) ) Defendants. ) LETTERIOUS ALEXANDER, ) ) Plaintiff, ) ) v. ) CV425-093 ) JEFFERY TISDALE, ) ) Defendant. ) ORDER These two cases involve civil claims arising out of a crash involving a prison transport bus near Savannah, Georgia. Pro se Plaintiff Letterious Alexander, who is currently incarcerated at Johnson State Prison, was being transferred from Jackson State Prison, in Butts County, Georgia, to Coastal State Prison in Chatham County in March 2023. See, e.g., CV425-015, doc. 1 at 3, 5. The first Complaint, filed in the Savannah Division, asserts 42 U.S.C. § 1983 claims against Defendant Sergeant Adams, the prison employee who drove the bus,

Defendants Sergeant Gaston and CERT Officer Zek, guards who supervised Alexander’s transportation, Defendants Pineiro and Glenn,

Warden and Deputy Warden, respectively, of Coastal State Prison, and Defendants Gibbs and Gillison, guards at Coastal State Prison. See CV425-015, doc. 1 at 5-7. Shortly after that Complaint was filed,

Alexander filed a second Complaint, which was assigned to this Court’s Dublin Division, and has now been transferred to the Savannah Division. See, e.g., CV425-093, doc. 12 (Order transferring case from the Dublin

Division). Judge Bowen recently found the second Complaint alleges a state law negligence claim against the driver of the vehicle that caused the prison bus to crash. See generally doc. 11. The Court enters this

Order to address several procedural issues in both cases. First, Alexander has failed to comply with the Court’s Order in CV425-015 permitting him to proceed in forma pauperis. See CV425-015,

doc. 5. The Court directed Alexander to return two forms to proceed in forma pauperis. See id. at 4-6. Alexander returned only one of the required forms. See CV425-015, doc. 10. As the Court’s Order explained, failure to return the forms timely would be construed as indicating “that plaintiff desires to have this case voluntarily dismissed.” CV425-015,

doc. 5 at 5. However, as discussed more fully below, Plaintiff’s submission of additional motions indicates, on the contrary, that he

wishes to pursue case CV425-015. See, e.g., CV425-015, doc. 9. The first issue that must be addressed, therefore, is whether Alexander wishes to pursue CV424-015. If he does, he must complete and return the missing

Consent to Collection of Fees from Trust Account form. If he wishes to pursue case number CV425-015, he is DIRECTED to return the missing form by no later than May 12, 2025. The Clerk is DIRECTED to enclose

a blank copy of the Consent to Collection of Fees from Trust Account form with this Order for Alexander’s convenience. Alexander is also DIRECTED to explain why he failed to return that form, as directed in

the Court’s prior Order. The Court will also address Alexander’s request for court-appointed counsel in CV425-015. See CV425-015, doc. 9. First, Alexander has no

constitutional right to counsel in either of these civil cases. Wright v. Langford, 562 F. App’x 769, 777 (11th Cir. 2014) (citing Bass v. Perrin, 170 F.3d 1312, 1320 (11th Cir. 1999)). “Although a court may, pursuant to 28 U.S.C. § 1915(e)(1), appoint counsel for an indigent plaintiff, it has broad discretion in making this decision, and should appoint counsel only

in exceptional circumstances.” Id. (citing Bass, 170 F.3d at 1320). Appointment of counsel in a civil case is a “privilege that is justified only

by exceptional circumstances, such as where the facts and legal issues are so novel or complex as to require the assistance of a trained practitioner.” Fowler v. Jones, 899 F.2d 1088, 1096 (11th Cir. 1990)

(citing Poole v. Lambert, 819 F.2d 1025, 1028 (11th Cir. 1987), and Wahl v. McIver, 773 F.2d 1169, 1174 (11th Cir. 1985)). General lack of education, including legal education, is also not a sufficient basis to

require appointment of counsel. See, e.g., Brown v. Wilcher, 2021 WL 411508, at *1 (S.D. Ga. Feb. 5, 2021). Moreover, this Court has repeatedly recognized that “prisoners do not receive special consideration

[for appointed counsel] notwithstanding the challenges of litigating a case while incarcerated.” Hampton v. Peeples, 2015 WL 4112435, at *2 (S.D. Ga. July 7, 2015). Finally, Alexander’s vague reference to “mental

health impairments,” doc. 9 at 1, is also not sufficient to require appointment of counsel. See, e.g., Kidwell v. Wagoner, 2011 WL 13175897, at *1 (M.D. Fla. Feb. 11, 2011).

The Eleventh Circuit has explained that “the key” to assessing whether counsel should be appointed “is whether the pro se litigant needs

help in presenting the essential merits of his or her position to the court. Where the facts and issues are simple, he or she usually will not need such help.” McDaniels v. Lee, 405 F. App’x 456, 457 (11th Cir. 2010)

(quoting Kilgo v. Ricks, 983 F.2d 189, 193 (11th Cir. 1993)). As Alexander’s filings in this case are clear and cogent, and the issues related to his constitutional claims are not complex, the Court does not

find any “exceptional circumstance” that warrants appointment of counsel. Fowler, 899 F.2d at 1096. His request for appointed counsel is, therefore, DENIED. CV425-015, doc. 9.

Prior to its transfer to this Division, CV425-093 was screened, see docs. 8 & 9, and Judge Bowen determined that “the case will proceed as a diversity case sounding in a state law claim of negligence,” doc 9 at 4.

He further directed that “[t]he Magistrate Judge shall initiate the appropriate procedure and issue any necessary order to move the case forward, including an inquiry into the appropriate venue for the case.” Id. Based on that instruction, Judge Epps transferred the case to this Division. CV425-093, doc. 12. The Court will, therefore, direct service

upon Defendant Tisdale. Since Alexander has been authorized to proceed in forma pauperis,

he is entitled to service by the United States Marshal. See Fed. R. Civ. P. 4(c)(3). Since the Court approved his state law negligence claim for service, a summons, a copy of his Complaint, CV425-093, doc. 1, Judge

Epps’ Report and Recommendation, CV425-093, doc. 8, Judge Bowen’s Order, CV425-093, doc. 11, the transfer Order, CV425-093, doc. 12, and this Order, shall be served by the United States Marshal upon Defendant

Tisdale without prepayment of cost. Fed. R. Civ. P. 4(e). The Court DIRECTS the Clerk of Court to serve a copy of this Order upon Plaintiff. The Court also provides the following instructions to the parties that will

apply to the remainder of this action. INSTRUCTIONS TO ALL DEFENDANTS IN THIS ACTION Because Plaintiff is proceeding in forma pauperis, the undersigned

directs service be effected by the United States Marshal. Fed. R. Civ. P. 4(c)(3).

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Related

Young v. City of Augusta Ex Rel. DeVaney
59 F.3d 1160 (Eleventh Circuit, 1995)
Albert W. McDaniels v. Caroline Lee
405 F. App'x 456 (Eleventh Circuit, 2010)
Peter Gerard Wahl v. William McIver
773 F.2d 1169 (Eleventh Circuit, 1985)
Reginald Lacroix Poole v. Larry Lambert
819 F.2d 1025 (Eleventh Circuit, 1987)
Willie Frank Wright, Jr. v. Officer Langford
562 F. App'x 769 (Eleventh Circuit, 2014)
Kilgo v. Ricks
983 F.2d 189 (Eleventh Circuit, 1993)

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Alexander v. Tisdale, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alexander-v-tisdale-gasd-2025.