Cook v. King County Correctional Facility

District Court, W.D. Washington·Decided August 2, 2021·No. 2:21-cv-00238·Unknown

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 8 JEFFREY A COOK, 9 Plaintiff, CASE NO. 2:21-cv-00238-RSM-BAT 10 v. ORDER DENYING MOTION FOR COUNSEL AND REQUESTS TO 11 KING COUNTY CORRECTIONAL AMEND, STRIKING DOCKET 33, FACILITY et al., DENYING MOTION FOR DISCOVERY, GRANTING IN PART 12 Defendant. AND DENYING IN PART REQUEST FOR EXTENSION, RE- 13 NOTING MOTION FOR SUMMARY JUDGMENT 14

This is a 42 U.S.C. § 1983 prisoner civil rights action. Currently pending before the Court 15 are Defendants’ motion for summary judgment (Dkt. 15), Plaintiff’s motion for appointment of 16 counsel (Dkt. 20), Plaintiff’s motion for substitution of defendants (Dkt. 21), Plaintiff’s motion 17 for extension of filing deadlines (Dkt. 22), Plaintiff’s “amendment to complaint” (Dkt. 33), 18 Plaintiff’s motion for discovery (Dkt. 36), Defendants’ motion to exclude Plaintiff’s 19 “amendment to complaint” (Dkt. 38), and Plaintiff’s motion to amend the complaint (Dkt. 40). 20 Having considered the parties’ submissions, the balance of the record, and the governing law, the 21 Court finds and ORDERS: 22 ORDER DENYING MOTION FOR COUNSEL 23 AND REQUESTS TO AMEND, STRIKING DOCKET 33, DENYING MOTION FOR DISCOVERY, GRANTING IN PART AND 1 2 A. Motion for Appointment of Counsel 3 Plaintiff moves for appointment of counsel based on his health and the complexity of the 4 issues in his case. Dkt. 20. Defendants oppose the motion. Dkt. 30.

5 Generally, a person has no right to counsel in a civil action. See Campbell v. Burt, 141 6 F.3d 927, 931 (9th Cir. 1998). In certain “exceptional circumstances,” the Court may request the 7 voluntary assistance of counsel for indigent civil litigants under 28 U.S.C. § 1915(e)(1). 8 Agyeman v. Corrections Corp. of Am., 390 F.3d 1101, 1103 (9th Cir. 2004). When determining 9 whether “exceptional circumstances” exist, the Court considers “the likelihood of success on the 10 merits as well as the ability of the [plaintiff] to articulate his claims pro se in light of the 11 complexity of the legal issues involved.” Weygandt v. Look, 718 F.2d 952, 954 (9th Cir. 1983). 12 Neither factor is dispositive, and they must be viewed together before reaching a decision on a 13 request for counsel. Id. 14 Plaintiff argues the Court should appoint counsel due to his health difficulties, indicating

15 that he will be undergoing surgery to remove a disc in his neck as well as eye surgery sometime 16 in the future. Dkt. 20. He also indicates he is experiencing an ongoing health issue wherein he 17 experiences seizures every 6 to 8 weeks and that after these seizures he experiences confusion, 18 disorganization, loss of memory and aggression and is only able to present organized argument 19 about half the time. Id. He also indicates he is experiencing headaches and his medications make 20 him drowsy. Id. Plaintiff also argues counsel should be appointed due to the complexity of the 21 issues in his case. Id. 22 ORDER DENYING MOTION FOR COUNSEL 23 AND REQUESTS TO AMEND, STRIKING DOCKET 33, DENYING MOTION FOR DISCOVERY, GRANTING IN PART AND 1 Considering both the likelihood of success on the merits and Plaintiff’s ability to 2 articulate his claims pro se in light of the complexity of the relevant legal issues, the Court 3 concludes that Plaintiff does not establish exceptional circumstances warranting appointment of 4 counsel at this time. Plaintiff fails to demonstrate that he is likely to succeed on the merits of his

5 claims at this point. Plaintiff offers little argument and points to no evidence in support of his 6 motion to appoint counsel to demonstrate that he is likely to succeed on the merits of the claims 7 raised in his complaint, nor is the Court able to conclude at this point in the litigation that 8 Plaintiff is, in fact, likely to succeed on the merits. 9 Furthermore, Plaintiff has demonstrated an adequate ability, up to this point, to articulate 10 his claims pro se, despite his medical condition. Plaintiff presents no medical evidence in support 11 of his motion demonstrating that his condition is limiting him to the extent that he is unable to 12 litigate his case at this time. Plaintiff’s numerous filings demonstrate an adequate ability on 13 Plaintiff’s part to articulate his allegations and to request relief. See Palmer v. Valdez, 560 F.3d 14 965, 970 (9th Cir. 2009) (where pro se civil rights plaintiff shows a good grasp of basic litigation

15 procedure and has been able to articulate claims adequately, he does not demonstrate exceptional 16 circumstances required for appointment of counsel). To the extent Plaintiff’s upcoming medical 17 procedures may impact his ability to timely respond to motions or otherwise litigate he may 18 move for extensions of time on that basis as appropriate. Furthermore, Plaintiff’s claims do not 19 appear, at this point, to present particularly complex issues of fact or law. Plaintiff primarily 20 argues that Defendants were deliberately indifferent to his serious medical needs in failing to 21 properly treat his medical conditions. This type of claim is addressed frequently in this Court and 22 the Court cannot conclude at this point that the facts of this case are so complex that counsel ORDER DENYING MOTION FOR COUNSEL 23 AND REQUESTS TO AMEND, STRIKING DOCKET 33, DENYING MOTION FOR DISCOVERY, GRANTING IN PART AND 1 should be appointed. Plaintiff also challenges the constitutionality of his guilty plea. However, 2 this claim also does not appear to the Court, at this point, to be of such a complex legal or factual 3 nature such that counsel should be appointed on this basis. 4 Accordingly, the Court finds that Plaintiff fails to demonstrate he is entitled to

5 appointment of counsel at this time. Plaintiff’s motion (Dkt. 20) is DENIED without prejudice. 6 B. Motion for Substitution of Defendant, “Amendment to Complaint”, Motion to 7 Exclude Plaintiff’s Amendment to Complaint, Motion to Amend Complaint 8 Plaintiff moves “for substitution of defendant” seeking to replace Defendants King 9 County Correctional Facility, Maeleng Regional Justice Center, and King County Courts with 10 King County which he asserts is the “proper legal entity representing the jail(s) and court.” Dkt. 11 21. Defendants oppose Plaintiff’s motion on the grounds that the amendment would likely be 12 futile in light of Defendants’ pending motion for summary judgment and based on Plaintiff’s 13 failure to attach a copy of the proposed amended pleading as required by Local Civil Rule (LCR) 14 15. Dkt. 28. Plaintiff has also filed a document entitled “Amendment to Complaint” which

15 appears to be a combined attempt to amend his complaint to add additional defendants and to 16 further respond to Defendants’ motion for summary judgment. Dkt. 33. Defendants move to 17 exclude Plaintiff’s “amendment to complaint” arguing that Plaintiff has not properly sought 18 leave of the Court to amend or complied with LCR 15. Dkt. 38. Plaintiff has also filed a motion 19 to amend his complaint in which he appears to seek to “add a Monell claim” but does not include 20 a complete proposed amended complaint. Dkt. 40. 21 Pursuant to Rule 15(a) of the Federal Rules of Civil Procedure

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