Cormia v. Crabtree

CourtDistrict Court, E.D. Tennessee
DecidedSeptember 15, 2025
Docket3:23-cv-00291
StatusUnknown

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

Bluebook
Cormia v. Crabtree, (E.D. Tenn. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT KNOXVILLE

DOLWIN CORMIA, ) ) Plaintiff, ) ) v. ) No. 3:23-CV-291-JEM ) SGT. CRABTREE and SGT. MOORE, ) ) Defendants. )

MEMORANDUM & ORDER Plaintiff, a prisoner of the Tennessee Department of Correction (“TDOC”), filed this pro se action for violation of 42 U.S.C. § 1983 that proceeded only as to Plaintiff’s claims that on June 7, 2023, Defendants used excessive force against him while he was restrained [Doc. 12 pp. 7–43]. Now before the Court are (1) Plaintiff’s motions to appoint counsel [Docs. 56, 60]; (2) Plaintiff’s motion for a form that will allow his friends and family to pay the balance of the filing fee for this action [Doc. 61]; (3) the parties’ discovery motions [Docs. 62–67]; and (4) Defendants Moore’s and Crabtree’s motions for summary judgment asserting that Plaintiff failed to exhaust his available administrative remedies prior to filing this action [Docs. 26, 41]. I. APPOINTMENT OF COUNSEL In his first motion to appoint counsel, Plaintiff states in relevant part that (1) “[he] is unable to afford counsel [and] has requeste[d] leave to proceed in forma pauperis”; (2) “[his] imprisonment will greatly limit his ability to litigate”; (3) “[he] is in administrative segregation on twenty-three hour lockdown, with limited access to the law library and its materials”; (4) “it takes a minimum of two weeks to request and receive materials from the law/legal library”; (5) “[t]he issues involved in this case are complex[] and will require significant time, research, and investigation”; (6) “[he] has very limited access to the law library and limited knowledge of the law”; (7) “[a] trial in this case will likely involve conflicting testimony, and counsel would better enable Plaintiff to present evidence and cross examine witnesses”; and (8) “Plaintiff has made repeated efforts to obtain a lawyer by writing and by family members, without response or success” [Doc. 56 pp. 1–2].

Plaintiff then filed a second motion requesting appointment of counsel that is substantively similar to his first [Doc. 60]. Plaintiff, however, adds allegations that although a prison policy allows inmates to check out books, when he requests materials and books from the law library, he receives pages from the book rather than the whole book, and the copies of the pages are not of the full page [Id. at 2]. To support these allegations, Plaintiff filed exhibits, including a prison form indicating books may be checked out and a copy of a page from a book that cut off a letter or two in one of the paragraphs on the page [Doc. 60-1]. Also in his second motion for appointment of counsel, Plaintiff (1) states that counsel would help him locate former employees and (2) names the lawyers he has contacted [Doc. 60 p. 2].

Appointment of counsel in a civil proceeding is not a constitutional right, but a privilege justified only in exceptional circumstances. Lavado v. Keohane, 992 F. 2d 601, 605‒06 (6th Cir. 1993). A district court has discretion to determine whether to appoint counsel for an indigent plaintiff. Reneer v. Sewell, 975 F.2d 258, 261 (6th Cir. 1992). In exercising that discretion, the district court should consider the nature of the case, whether the issues are legally or factually complex, and the plaintiff’s ability to present his claims. Lavado, 992 F.2d at 605–06. As to the first two factors, as set forth above, this action is proceeding only as Plaintiff’s excessive force claims, which are routine claims that are not factually or legally complex. Plaintiff’s allegations regarding the conditions of his incarceration, self-representation, and lack of an attorney are typical of prisoner plaintiffs. As to the third factor, it is apparent from his filings that Plaintiff can adequately present his claims. Moreover, while Plaintiff alleges he has had difficulty obtaining specific legal materials, the Court does not infer that this has caused him any problems in this proceeding. Thus, Plaintiff has not established that this is an exceptional case where he is entitled to

appointment of counsel, and his motions for appointment of counsel [Docs. 56, 60] are DENIED. II. FORM REQUEST Plaintiff filed a motion requesting that the Court provide him with a form, application, or methods that will allow his friends and family to pay the balance of his filing fee [Doc. 61]. This motion [Doc. 61] is GRANTED to the extent that the Clerk is DIRECTED to send a copy of this memorandum and order to the Court’s financial officer, who is DIRECTED to send Plaintiff (1) the balance of his filing fee for this action and (2) any guidance that may exist as to how Plaintiff’s friends and family may pay that balance, including any form that may exist. III. DISCOVERY MOTIONS

More than five months after Plaintiff filed his last response to a pending motion for summary judgment [Doc. 54], Plaintiff filed numerous documents with the Court through which he appears to seek discovery from Defendants [Docs. 62–66]. Defendants filed a motion [Doc. 67] and memorandum [Doc. 67-1] opposing these filings. In their memorandum, Defendants assert that Plaintiff’s discovery filings with the Court are inappropriate before requesting that the Court dismiss Plaintiff’s discovery requests and suspend the current discovery deadline until after the Court rules on their pending motions for summary judgment or, in the alternative, extend their time to respond to these discovery motions [Doc. 67-1 pp. 1–5]. Initially, it appears likely that Plaintiff filed these discovery documents [Docs. 62–66] with the Court for the purpose of serving them on Defendants as discovery requests. But this was improper, as the Court’s Local Rule provides that parties may not file discovery documents with the Court except under certain circumstances that are not applicable here. See E.D. Tenn. L.R. 5.3. To the extent that Plaintiff filed these discovery documents [id.] with the Court for the

purpose of requesting that the Court compel Defendants to answer the discovery requests therein, this is also improper. Specifically, as Defendants correctly point out in their memorandum in support of their discovery motion [Doc. 67-1 pp. 2–3], Rule 37(a)(1) of the Federal Rules of Civil Procedure requires litigants seeking to compel discovery from an opposing party to file a certificate indicating that they conferred or attempt to confer with the opposing party about the discovery dispute prior to seeking relief from the Court regarding that dispute. Fed. R. Civ. P. 37(a)(1) (providing that a motion seeking to compel discovery “must include a certification that the movant has in good faith conferred or attempted to confer with the person or party failing to make disclosure or discovery in an effort to obtain it without court action”). None of Plaintiff’s discovery

filings [Docs. 62–66] comply with this rule, as they do not contain the required certification. It is also apparent from (1) the timing of Plaintiff’s discovery filings [id.] and (2) the fact that none of Plaintiff’s discovery filings [id.] appear to be aimed at obtaining discovery regarding Plaintiff’s exhaustion of his administrative remedies that Plaintiff does not assert that he is entitled to obtain the requested discovery prior to the Court ruling on Defendants’ pending motions seeking summary judgment [Docs. 26, 41]. But even if the Court could liberally construe Plaintiff’s discovery filings [Docs.

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Cormia v. Crabtree, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cormia-v-crabtree-tned-2025.