Garland Pittman v. Ofc Clayton

District Court, M.D. Georgia·Decided July 13, 2026·No. 3:25-cv-00085·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA ATHENS DIVISION

GARLAND PITTMAN, : : Plaintiff, : : v. : Case No. 3:25-cv-85-TES-AGH : OFC CLAYTON, : : Defendant. : ________________________________

ORDER AND RECOMMENDATION Before the Court are Defendant’s motion to dismiss (ECF No. 15) and Plaintiff’s motion to appoint counsel (ECF No. 8). For the reasons stated below, it is recommended that Defendant’s motion to dismiss be granted. Plaintiff’s motion to appoint counsel is denied. BACKGROUND Plaintiff claims that on August 10, 2023, he and another inmate began fighting in his cell at Macon State Prison (“MSP”). Compl. 5, ECF No. 1. Plaintiff then began beating on his cell door to notify Officer Clayton that Plaintiff needed assistance in his cell. Id. Officer Clayton came to Plaintiff’s cell and saw that Plaintiff and his cellmate were fighting. Id. Rather than break up the fight, Officer Clayton left Plaintiff to continue fighting “for [his] life.” Id. Plaintiff does not say how the fight ended, but he asserts that the cellmate “is now deceased.” Id. Plaintiff further states in his complaint that he filed a grievance on October 10, 2023, at Valdosta State Prison (“VSP”), which is where he was moved after the incident with his cellmate. Compl. 3. Plaintiff claims that he could not file the grievance at MSP because he was in a suicide cell, presumably until he moved to VSP. Id. Plaintiff moved for appointment of counsel on November 24, 2025 (ECF No. 8).

Defendant Clayton then moved to dismiss Plaintiff’s complaint for failure to exhaust his administrative remedies on February 5, 2026. Def.’s Mot. to Dismiss 1, ECF No. 41. On February 6, 2026, the Court notified Plaintiff of his right to respond and explained to Plaintiff that his failure to respond may result in the court accepting the statements in the motion as being uncontested. Plaintiff failed to respond to the motion. These motions are ripe for review. DISCUSSION

I. Motion to Appoint Counsel Plaintiff moves for appointment of counsel in this case.1 ECF No. 8. “Appointment of counsel in a civil case is not a constitutional right.” Fowler v. Jones, 899 F.2d 1088, 1096 (11th Cir. 1990). “A court’s appointment of counsel in a civil case is warranted only in exceptional circumstances, and whether such circumstances exist is committed to the district court’s discretion.” Smith v. Fla. Dep’t of Corr., 713

F.3d 1059, 1063 (11th Cir. 2013) (citing Steele v. Shah, 87 F.3d 1266, 1271 (11th Cir. 1996)). In determining whether a case presents extraordinary circumstances, the Court considers:

1 The federal IFP statute authorizes courts to “request an attorney to represent any person unable to afford counsel.” 28 U.S.C. § 1915(e)(1). The statute does not, however, provide any funding to pay counsel for their representation or authorize courts to compel counsel to represent an indigent party in a civil action. See Mallard v. U.S. Dist. Ct. for S. Dist. of Iowa, 490 U.S. 296, 310 (1989); Taylor v. Pekerol, 760 F. App’x 647, 651 (11th Cir. 2019) (stating that district court has no “inherent power” to compel counsel to represent a civil litigant and § 1915 provides no such authority). (1) the type and complexity of the case; (2) whether the plaintiff is capable of adequately presenting his case; (3) whether the plaintiff is in a position to adequately investigate the case; (4) whether the evidence “will consist in large part of conflicting testimony so as to require skill in the presentation of evidence and in cross examination”; and (5) whether the appointment of counsel would be of service to the parties and the court “by sharpening the issues in the case, shaping the examination of witnesses, and thus shortening the trial and assisting in a just determination.” The District Court may also inquire into whether the plaintiff has made any effort to secure private counsel.

DeJesus v. Lewis, 14 F.4th 1182, 1204-05 (11th Cir. 2021) (quoting Ulmer v. Chancellor, 691 F.2d 209, 213 (5th Cir. 1982)). The Court considered Plaintiff’s motion and—after applying the factors set forth above—concludes that the appointment of counsel is not justified. Plaintiff has demonstrated the ability to litigate his case, including filing pleadings and motions sufficiently setting out his contentions to allow review by the Court. Plaintiff, “like any other litigant[], undoubtedly would [be] helped by the assistance of a lawyer, but [his] case is not so unusual” that appointed counsel is necessary. Bass v. Perrin, 170 F.3d 1312, 1320 (11th Cir. 1999). Plaintiff’s motion for appointment of counsel (ECF Nos. 8) is consequently denied. II. Defendant’s Motion to Dismiss A. Exhaustion Standard The Prison Litigation Reform Act (“PLRA”) provides that “[n]o action shall be brought with respect to prison conditions under section 1983 of this title . . . by a prisoner confined in any jail, prison, or other correctional facility until such administrative remedies as are available are exhausted.” 42 U.S.C. § 1997e(a). When a grievance procedure is provided for prisoners, “an inmate alleging harm suffered from prison conditions must file a grievance and exhaust the remedies available under that procedure before pursuing a § 1983 lawsuit.” Brown v. Sikes, 212 F.3d 1205, 1207 (11th Cir. 2000) (emphasis added). “To exhaust administrative

remedies in accordance with the PLRA, prisoners must properly take each step within the administrative process. If their initial grievance is denied, prisoners must then file a timely appeal.” Bryant v. Rich, 530 F.3d 1368, 1378 (11th Cir. 2008) (internal citation and quotation marks omitted). “Proper exhaustion demands compliance with an agency’s deadlines and other critical procedural rules because no adjudicative system can function effectively without imposing some orderly structure on the course of its proceedings.” Woodford v. Ngo, 548 U.S. 81, 90-91 (2006).

“The level of detail necessary in a grievance to comply with the grievance procedures will vary from system to system and claim to claim, but it is the prison’s requirements, and not the PLRA, that define the boundaries of proper exhaustion.” Jones v. Bock, 549 U.S. 199, 218 (2007). “The critical function of the grievance process is that it provides the institution with notice of a problem such that they have an opportunity to address the problem internally.” Toenniges v. Ga. Dep’t of Corr.,

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