Floyd Parker v. Jonathan Ek, et al.

CourtDistrict Court, C.D. Illinois
DecidedFebruary 2, 2026
Docket2:25-cv-02143
StatusUnknown

This text of Floyd Parker v. Jonathan Ek, et al. (Floyd Parker v. Jonathan Ek, et al.) is published on Counsel Stack Legal Research, covering District Court, C.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Floyd Parker v. Jonathan Ek, et al., (C.D. Ill. 2026).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS URBANA DIVISION

FLOYD PARKER, ) ) Plaintiff, ) ) v. ) 2:25-cv-02143-MMM ) JONATHAN EK, et al. ) ) Defendants. )

ORDER Plaintiff, proceeding pro se and presently incarcerated at Lawrence Correctional Center, alleges Defendants violated his Eighth Amendment rights through deliberate indifference to his serious medical needs while he was incarcerated at Danville Correctional Center. I. Motion to Request Counsel Plaintiff’s Motions to Request Counsel are before the Court. Docs. 5, 6, 7. Legal Standard for Request for Counsel The Seventh Circuit has summarized the legal standard that governs Plaintiff’s request for counsel as follows: Under 28 U.S.C. § 1915(e)(1), a federal court “may request an attorney to represent any person unable to afford counsel.” The statute is “entirely permissive.” Pruitt v. Mote, 503 F.3d 647, 654 (7th Cir. 2007) (en banc). Civil litigants have no constitutional or statutory right to court-appointed counsel, and § 1915(e)(1) “does not authorize the federal courts to make coercive appointments of counsel.” Id. at 653 (quoting Mallard v. U.S. Dist. Court for S. Dist. of Iowa, 490 U.S. 296, 310, 109 S.Ct. 1814, 104 L.Ed.2d 318 (1989)). Rather, the statute “codifies the court’s discretionary authority to recruit a lawyer to represent an indigent civil litigant pro bono publico.” Id. “Almost everyone would benefit from having a lawyer, but there are too many indigent litigants and too few lawyers willing and able to volunteer for these cases.” Olson v. Morgan, 750 F.3d 708, 711 (7th Cir. 2014). “District courts are thus placed in the unenviable position of identifying, among a sea of people lacking counsel, those who need counsel the most.” Id.

Accordingly, we have recently explained that “the decision whether to recruit a lawyer for a particular plaintiff is made against the twofold backdrop of a high volume of indigent, pro se litigants (particularly incarcerated individuals) and a small pool, by comparison, of attorneys willing and able to take those cases on pro bono.” Watts v. Kidman, 42 F.4th 755, 763 (7th Cir. 2022). Based on these and other practical considerations, we have held that district judges should engage in a two-step inquiry when faced with a request for pro bono counsel under § 1915(e)(1), asking first “(1) has the indigent plaintiff made a reasonable attempt to obtain counsel or been effectively precluded from doing so; and if so, (2) given the difficulty of the case, does the plaintiff appear competent to litigate it himself?” Pruitt, 503 F.3d at 654.

The first step needs no elaboration. Step two “can be complex” and involves a pragmatic judgment about the difficulty of the case and the plaintiff’s ability to present it to the court on his own. Watts, 42 F.4th at 760. “The inquiries are necessarily intertwined; the difficulty of the case is considered against the plaintiff’s litigation capabilities, and those capabilities are examined in light of the challenges specific to the case at hand.” Pruitt, 503 F.3d at 655. A judge will normally consider “the plaintiff’s literacy, communication skills, educational level, and litigation experience” along with any evidence in the record “bearing on the plaintiff’s intellectual capacity and psychological history.” Id. But these are merely factors that are ordinarily relevant. No one factor is “necessary or conclusive.” Id. at 655 n.9. Indeed, “[t]here are no fixed requirements for determining a plaintiff’s competence to litigate his own case.” Id. at 655. Ultimately, the “inquiry into the plaintiff’s capacity to handle his own case is a practical one, made in light of whatever relevant evidence is available on the question.” Id.

Finally, “the decision whether to recruit pro bono counsel is left to the district court’s discretion.” Id. at 654. Our job is to ensure that this discretion is exercised in accordance with appropriate legal principles. The “question on appellate review is not whether we would have recruited a volunteer lawyer in the circumstances, but whether the district court applied the correct legal standard and reached a reasonable decision based on facts supported by the record.” Id. at 658. Jones v. Anderson, 116 F.4th 669, 675-76 (7th Cir. 2024). In determining the second step, the Court should view the case through the lens of certain specific factors that the

Seventh Circuit has enumerated: Though this inquiry must be case-and plaintiff-specific, we have identified circumstances that tend to diminish a prisoner-plaintiff’s ability to litigate pro se, such as when: (1) the case reaches later stages of litigation, (2) the plaintiff is transferred to another facility and loses access to relevant witnesses or evidence, (3) the claim depends on the state of mind of the defendant, and (4) expert testimony is necessary to prove the claim.

Owens v. Wexford Health Sources, et al., No. 22-2882, 2024 WL 5242367, at *3 (7th Cir. Dec. 30, 2024), citing James v. Eli, 889 F.3d 320, 327-28 (7th Cir. 2018). Analysis as to Request for Counsel First, Plaintiff has shown a reasonable attempt to obtain counsel on his own, having written to several attorneys asking for assistance, without success. Second, Plaintiff is able to represent himself. Plaintiff’s claims are not factually difficult; he alleges the pain care he received was insufficient. Plaintiff has personal knowledge of his claims and treatment and can testify to what he experienced. Written discovery would produce to Plaintiff the relevant written medical and prison records related to his claims. Plaintiff’s claims are also not particularly legally difficult, though all federal litigation is difficult to a degree. He would be required to prove the mental state of the Defendants which makes this consideration somewhat favor a counsel search. Plaintiff’s pleadings are clear, legible, and coherent. Plaintiff’s education level is that of a high school graduate, and he appears well able to communicate. There is no information before the Court that indicates Plaintiff is mentally impaired to the extent that he cannot represent himself. Plaintiff reports he has no legal education or

experience. And considering the circumstances the Seventh Circuit suggested in Owens, none weigh heavily in favor of a search for counsel on the specific facts here. The case is at its outset. Plaintiff has been transferred to Lawrence from Danville, but there is nothing before the Court indicating that the transfer would particularly hamper Plaintiff’s ability to conduct discovery or otherwise litigate the case. There is a state of mind

element to Plaintiff’s claims as discussed above. Expert testimony may be implicated in this action, though at this time Plaintiff’s allegations, accepted as true, do not state a claim. It appears the overall likelihood of success of Plaintiff’s action is much lower than many other lawsuits of this nature. In an exercise of its discretion, assessing the factors and the record in this case,

the Court finds Plaintiff can continue representing himself here. II. Merit Review The Court must “screen” Plaintiff’s complaint, and through such process identify and dismiss any legally insufficient claim, or the entire action if warranted. 28 U.S.C.

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Related

Burks v. Raemisch
555 F.3d 592 (Seventh Circuit, 2009)
Pruitt v. Mote
503 F.3d 647 (Seventh Circuit, 2007)
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Gregory Turley v. Dave Rednour
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721 F.3d 418 (Seventh Circuit, 2013)
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792 F.3d 768 (Seventh Circuit, 2015)
Tyrone Petties v. Imhotep Carter
836 F.3d 722 (Seventh Circuit, 2016)
Thomas James v. Lorenzo Eli
889 F.3d 320 (Seventh Circuit, 2018)
William Watts v. Mark Kidman
42 F.4th 755 (Seventh Circuit, 2022)
Benjamin Adams v. Christina Reagle
91 F.4th 880 (Seventh Circuit, 2024)
Brian Jones v. Theodore Anderson
116 F.4th 669 (Seventh Circuit, 2024)

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Bluebook (online)
Floyd Parker v. Jonathan Ek, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/floyd-parker-v-jonathan-ek-et-al-ilcd-2026.