Huertas v. Waite

CourtDistrict Court, E.D. Wisconsin
DecidedJanuary 11, 2021
Docket2:19-cv-00592
StatusUnknown

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

Bluebook
Huertas v. Waite, (E.D. Wis. 2021).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN ______________________________________________________________________________ NEHEMIAS HUERTAS, JR.

Plaintiff, v. Case No. 19-cv-0592-bhl

TAYLOR E. WAITE, et al.,

Defendants. ______________________________________________________________________________

ORDER ______________________________________________________________________________ BACKGROUND On April 24, 2019, plaintiff Nehemias Huertas, a Wisconsin state prisoner who is representing himself, filed this lawsuit under 42 U.S.C. §1983, alleging that seven defendants violated his civil rights. Dkt. No. 1. On November 14, 2019, Huertas filed a motion to amend the complaint, along with a proposed amended complaint, through which he sought to add 18 defendants, including a number of unidentified “Jane Doe” defendants, while dismissing his claims against three parties named in the original complaint. Dkt. No. 12. On February 19, 2020, the Court allowed the proposed amendment and proceeded to screen the amended complaint. Dkt. No. 18. In the screening order, the Court ruled that Huertas could proceed with Fourteenth Amendment medical care claims against several of the defendants, including three nurses who were only partially identified and seven “Jane Doe” defendants.” Id. at 8. The Court dismissed Huertas’ claims against the remaining defendants. Id. Since the screening order, substantial time and effort has been expended to serve the amended complaint and screening order on the defendants, and counsel have appeared for several of them. Dkt. Nos. 23-24, 29, 37, 39, 52, and 57. All of these defendants have now answered the complaint. Dkt. Nos. 25, 36, 40, 42, 58, and 71. Despite repeated efforts, service has not been made on defendants Jennifer Sabatier and “Nurse Scott.” Dkt. No. 68. On November 9, 2020, the Court received a letter from attorney Ryan Wiesner explaining that both Sabatier and Nurse Scott are former WellPath employees and that Wiesner therefore cannot accept service for them. Dkt. No. 69. Wiesner further explained that he has attempted to locate these individuals to assist the Court and the U.S. Marshals in completing service, but he has been unsuccessful. Id. Thus, Sabatier and Nurse Scott remain unserved. In the midst of these service efforts, Huertas has filed four additional motions. On March

17, 2020, he filed a motion to appoint counsel. Dkt. No. 35. On May 20, 2020, he filed a motion for leave to amend the complaint. Dkt. No. 44. On September 18, 2020, he filed yet another motion for leave to amend the complaint, hoping to add ten more defendants, to “correct” his claims against three of the existing defendants, and to bring back into the lawsuit one of the defendants, Corrections Office Morton, that was dismissed in the February 19, 2020 screening order. Dkt. No. 53. The proposed second amended complaint is 39-pages long. Dkt. No. 53-1. Finally, on December 21, 2020, Huertas filed a “Motion to Introduce Relevant and Essential Evidence.” Dkt. No. 77. All the defendants who have appeared oppose the motions to amend. Dkt. Nos. 59, 62 and 72.1 The defendants collectively oppose the motion to amend because the allegations are vague,

difficult to read, and contain many new details that may be easily missed. Dkt. No. 59. The defendants also note that this case was filed almost two years ago, and presumably, they want to move this case along without having to wait for service and answers from ten more defendants. ANALYSIS 1. Motion to Appoint Counsel

1 Rather than independently responding, several defendants have moved to join the oppositions filed by other defendants. The Court will grant the defendants’ motions to join responses. In his motion to appoint counsel, Huertas states that he is indigent and unable to afford counsel; that he has a 2.0 reading level, no high school degree, and a learning disability; and that the jailhouse lawyers who have been helping him with the lawsuit are not reliable sources of assistance because they come and go from the institution. Dkt. No. 35. Huertas also states that he has attempted to recruit counsel on his own but has been unsuccessful. Id. In a civil case, the Court has discretion to recruit a lawyer for individuals who cannot afford to hire one. Navejar v. Iyola, 718 F.3d 692, 696 (7th Cir. 2013); 28 U.S.C. §1915(e)(1); Ray v.

Wexford Health Sources, Inc., 706 F.3d 864, 866-67 (7th Cir. 2013). “[D]eciding whether to recruit counsel ‘is a difficult decision: 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.’” Henderson v. Ghosh, 755 F.3d 559, 564 (7th Cir. 2014) (quoting Olson v. Morgan, 750 F.3d 708, 711 (7th Cir. 2014)). In exercising its discretion, the Court must consider two things: “(1) ‘has the indigent plaintiff made a reasonable attempt to obtain counsel or been effectively precluded from doing so,’ and (2) ‘given the difficulty of the case, does the plaintiff appear competent to litigate it himself?’” Pennewell v. Parish, 923 F.3d 486, 490 (7th Cir. 2019) (quoting Pruitt v. Mote, 503 F.3d 647, 653 (7th Cir. 2007)). To satisfy the first prong, the Court must determine that a plaintiff made a good faith effort

to hire counsel. Pickett v. Chicago Transit Authority, 930 F.3d 869, 871 (7th Cir. 2019). To do so, Huertas must show he contacted at least three lawyers and provide the Court with (1) the lawyers’ names; (2) their addresses; (3) how and when the plaintiff attempted to contact the lawyer; and (4) the lawyers’ responses. When considering the second prong, the Court “must examine the difficulty of litigating specific claims and the plaintiff’s individual competence to litigate those claims without counsel.” Pennewell, 923 F.3d at 490. The Court looks at “whether the difficulty of the case, factually, legally, and practically, exceeds the litigant’s capacity as a layperson to coherently litigate the case.” Id. This includes “all tasks that normally attend litigation,” such as “evidence gathering, preparing and responding to court filings and motions, navigating discovery, and putting on a trial.” Id. at 490-491. The Court “must consider the plaintiff’s literacy, communication skills, education level, litigation experience, intellectual capacity, psychological history, physical limitations and any other characteristics that may limit the plaintiff’s ability to litigate the case.” Id. at 491. In situations where the plaintiff files his motion in the early stages of the case, the Court

may determine that it is “impossible to tell whether [the plaintiff] could represent himself adequately.” Pickett, 930 F.3d at 871. The Court is satisfied that Huertas made reasonable attempts to recruit counsel on his own. See Dkt. No. 35-1 at 9-20. However, it will not recruit counsel at this time. Huertas states that he is indigent and does not have a high school degree, but those circumstances are not unique to the plaintiff or this case. Many, if not most, prisoner-plaintiffs find themselves in similar circumstances.

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Bluebook (online)
Huertas v. Waite, Counsel Stack Legal Research, https://law.counselstack.com/opinion/huertas-v-waite-wied-2021.