Craigo v. Hey

345 S.E.2d 814, 176 W. Va. 514, 1986 W. Va. LEXIS 490
CourtWest Virginia Supreme Court
DecidedJune 6, 1986
Docket17085, 17086
StatusPublished
Cited by6 cases

This text of 345 S.E.2d 814 (Craigo v. Hey) is published on Counsel Stack Legal Research, covering West Virginia Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Craigo v. Hey, 345 S.E.2d 814, 176 W. Va. 514, 1986 W. Va. LEXIS 490 (W. Va. 1986).

Opinion

NEELY, Justice:

Robert Gary Craigo and James M. Oxier are indigent prisoners. Each has brought a civil suit in his own name, and each has had little success in prosecuting his action. Although we have held that a convict may sue in his own name, Craigo v. Marshall, 175 W.Va. 72, 331 S.E.2d 510 (1985), we have not detailed what aid the State of West Virginia must provide to indigent convicts to bring civil suits. Today we hold that indigent convicts enjoy the same right to legal aid as indigent freemen, but no more.

I

Mr. Craigo alleged in his petition for a writ of mandamus in this court that two Kanawha County circuit court judges have refused to docket his civil action pursuant to 42 U.S.C. § 1983 [1979] against the May- or of Charleston and “certain City of Charleston police officials”. Chief Judge A. Andrew MacQueen answered that he has reinstated Mr. Craigo’s action to the active docket of his court. Accordingly, we dismiss Mr. Craigo’s mandamus petition as moot.

Mr. Oxier has petitioned this Court for a writ of mandamus to compel the Circuit Court of Randolph County to appoint counsel. His legal assistance problems arise from suits he has filed as plaintiff in the Circuit Court of Randolph County over alleged personal injuries. The defendants’ attorneys in these suits by Mr. Oxier have filed motions to dismiss Mr. Oxier’s claims on the grounds that they were brought outside the two-year statute of limitations. Mr. Oxier states that he does not know what further action to take, because he does not have an attorney; no attorney will take his case; and, he does not possess the requisite legal knowledge to prosecute his cases himself.

*517 II

We have come a long way from the days when conviction of a criminal offense carried with it the penalty of “civil death,” a doctrine under which society stripped a convict of his right to sue. Furthermore, in an earlier case involving Mr. Craigo, we held that a convict is free to file a civil action without having of a committee appointed pursuant to W.Va.Code, 28-5-33 [1982], or by using a “next friend” pursuant to W. Va.R. Civ.P. 17(c). Syl. Pt. 1, Craigo v. Marshall, 175 W.Va. 72, 331 S.E.2d 510 (1985). Although we have removed most of the barriers to access to the courts that a convict has historically faced, we have not detailed the affirmative actions the state must take to insure that this access to the courts is meaningful. Even in cases where there is no absolute right to counsel, the peculiar circumstances of a case may make the assistance of counsel necessary.

At the outset we note that we exclude criminal cases from our analysis here. The 6th and 11th Amendments to the Constitution of the United States require the appointment of counsel for an indigent in all criminal proceedings. Gideon v. Wainwright, 372 U.S. 335, 83 S.Ct. 792, 9 L.Ed.2d 799 (1963). Additionally, prisoners are entitled to assistance of counsel in cases involving fundamental constitutional rights raised in civil habeas corpus proceedings. 1 But these holdings have no bearing on the question before us today concerning whether prisoners have a right to court-appointed counsel in ordinary civil actions.

Indigent civil litigants do not have a constitutional or statutory right to legal representation in all cases. “Nevertheless, particularly when rights of a constitutional dimension are at stake, a poor person’s access to the federal courts must not be turned into an exercise in futility. See Bounds v. Smith, 430 U.S. 817, 821-824 [97 S.Ct. 1491, 1494-1496, 52 L.Ed.2d 72] (1977); Haines v. Kerner, 404 U.S. 519, 520 [92 S.Ct. 594, 595, 30 L.Ed.2d 652] (1972).” Merritt v. Faulkner, 697 F.2d 761 (7th Cir.1983). The principle of meaningful access is reflected in many decisions by the Supreme Court of the United States, lower federal courts, and the state courts. Furthermore, Congress in 28 U.S.C. § 1915 [1979], 2 and the West Virginia Legislature in W.Va.Code, 59-2-1 [1923] 3 have indi *518 cated that the courts must be available to the rich and poor alike.

It has long been noted that it is not' necessary to provide legal assistance for every conceivable civil claim prisoners wish to process. Both the courts and the legal-assistance agencies themselves have the right to determine which claims merit legal assistance. Kelsey v. State of Minnesota, 622 F.2d 956, 958 n. 2 (8th Cir.1980); See generally Johnson v. Avery, 393 U.S. 483, 488, 89 S.Ct. 747, 750, 21 L.Ed.2d 718 (1969). But although trial courts have no duty to appoint counsel to represent indigent civil litigants, imprisoned or not, 28 U.S.C. § 1915 [1979] and W.Va.Code, 59-2-1 [1923] endow trial courts with the discretion to do so. Willett v. Wells, 469 F.Supp. 748 (E.D.Tenn.1977) aff'd without opinion 595 F.2d 1227 (6th Cir.1979) (interpreting 28 U.S.C. § 1915). And although the trial courts must exercise this discretion on a case by case basis, we can identify certain classes of cases where appointment of counsel will usually be proper and certain classes where appointment will seldom be proper.

It is impossible to establish hard- and-fast guidelines for the appointment of counsel for indigent prisoners, but it is possible to sketch a general typology that will provide a frame of reference for the intelligent use of discretion. Three general classes of cases emerge as follows: (1) Civil cases where the state has traditionally provided legal aid to indigents such as di vorce, paternity, or the termination of parental rights, (2) fee generating cases, and (3) civil rights cases. In the first type of case there is a presumption in favor of appointing counsel for defendants; in the second type there is a presumption against appointing counsel; and, in the third type the circuit court should apply a five factor test before deciding whether to appoint counsel for the preparation of the petitioner’s complaint.

A. CIVIL CASES WHERE THE STATE HAS TRADITIONALLY PROVIDED LEGAL AID TO INDIGENTS

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Bluebook (online)
345 S.E.2d 814, 176 W. Va. 514, 1986 W. Va. LEXIS 490, Counsel Stack Legal Research, https://law.counselstack.com/opinion/craigo-v-hey-wva-1986.