Hyatt v. Owens

CourtDistrict Court, D. Kansas
DecidedAugust 20, 2025
Docket6:25-cv-01171
StatusUnknown

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

Bluebook
Hyatt v. Owens, (D. Kan. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

TODD ROSS HYATT,

Plaintiff,

v. Case No. 25-1171-JWB-BGS

CLARK V. OWENS, ET AL.,

Defendant.

REPORT & RECOMMENDATION ON APPLICATION, MEMORANDUM & ORDER ON MOTION FOR APPOINTMENT OF COUNSEL and REPORT & RECOMMENDATION FOR DISMISSAL

In his Complaint, Plaintiff Todd Ross Hyatt alleges that the five named Defendants, acting under color of state law violated his Constitutional rights and 42 U.S.C. § 1983. (Doc. 1.) In conjunction with his Complaint, Plaintiff filed an “Application to Proceed in District Court Without Prepaying Fees or Costs” (In forma Pauperis or IFP application) (Doc. 3, sealed) and a motion for appointment of counsel (Doc. 4). For the reasons set forth herein, Plaintiff’s request for counsel (Doc. 4) is DENIED. The undersigned Magistrate Judge also recommends to the District Court that Plaintiff’s IFP application (Doc. 3, sealed) be DENIED and that his Complaint (Doc. 1) be DISMISSED for failing to state a viable federal cause of action. I. Application to Proceed (Doc. 3). Under 28 U.S.C. § 1915(a), a federal court may authorize commencement of a civil action “without prepayment of fees or security therefor, by a person who submits an affidavit that . . . the person is unable to pay such fees or give security therefor.” To succeed on an IFP motion, “the movant must show a financial inability to pay the required filing fees.” Lister v. Dep’t of Treasury, 408 F.3d 1309, 1312 (10th Cir. 2005). Proceeding IFP “in a civil case is a privilege, not a right – fundamental or otherwise.” White v. Colorado, 157 F.3d 1226, 1233 (10th Cir. 1998). The decision to grant or deny IFP status under § 1915 lies within the District Court’s sound discretion. Engberg v. Wyoming, 265 F.3d 1109, 1122 (10th Cir. 2001). The financial information provided by Plaintiff does not show that he is unable to pay the filing fee. In the interest of keeping Plaintiff’s personal finances confidential, the Court will not divulge the specific numbers he has submitted. That stated, the financial information establishes

that Plaintiff has a positive net monthly income after accounting for all listed expenses that is considerably higher than that of most pro se plaintiffs who move for IFP status. (See generally Doc. 3, sealed.) All things considered, the information provided by Plaintiff does not establish he is unable to pay the required filing fee. See, e.g., Otudeko v. Topeka Pub. Sch., No. 24-4082-DDC-RES, 2024 WL 5110073, at *1 (D. Kan. Aug. 30, 2024), report and recommendation adopted, No. 24-4082-DDC-RES, 2024 WL 5106712 (D. Kan. Dec. 13, 2024) (recommending that the plaintiff’s motion to proceed IFP be denied); Young v. Schmidt, No. 20-1268-EMF-GEB, 2021 WL 7710878, at *2 (D. Kan. Apr. 8, 2021), report and recommendation adopted, No. 20-1268-EFM, 2021 WL 7710876 (D. Kan. May 5, 2021) (same); Martinez Olivares v. Harvestland Constructors Inc., No. 24-2191-HLT-ADM, 2024 WL 3071090, at *1 (D. Kan. May 6, 2024), report and recommendation adopted, No. 2:24-CV-02191-HLT-ADM, 2024 WL 3066208 (D. Kan. June 20, 2024) (same); see also, e.g., Epson v. Astrue, No. 08-2349-CM, 2008 WL 4083013, *1 (D. Kan. Aug. 29, 2008) (affirming a report and recommendation of denial of IFP status where the plaintiff’s financial affidavit demonstrated a positive monthly income).

The Tenth Circuit has held that a magistrate judge does not have the authority under 28 U.S.C. § 636 to deny a plaintiff’s application to proceed IFP. Lister v. Dep’t of Treasury, 408 F.3d 1309, 1312-13 (10th Cir. 2005). The undersigned Magistrate Judge thus RECOMMENDS to the District Court that Plaintiff’s motion to proceed in forma pauperis (Doc. 3) be DENIED and that Plaintiff be directed to pay the filing fee within thirty days of an order from the District Court if the Report and Recommendation is adopted. The Magistrate Judge further RECOMMENDS that if Plaintiff does not pay the required filing fee within thirty days of any such District Court Order, this case be DISMISSED without prejudice. II. Request for Counsel (Doc. 4). As an initial matter, the Court notes there is no constitutional right to have counsel appointed in civil cases such as this one. Beaudry v. Corr. Corp. of Am., 331 F.3d 1164, 1169 (10th Cir.

2003). “[A] district court has discretion to request counsel to represent an indigent party in a civil case” pursuant to 28 U.S.C. § 1915(e)(1). Commodity Futures Trading Comm’n v. Brockbank, 316 F. App’x 707, 712 (10th Cir. 2008). The decision whether to appoint counsel “is left to the sound discretion of the district court.” Lyons v. Kyner, 367 F. App’x 878, n.9 (10th Cir. 2010) (citation omitted). The Tenth Circuit has identified four factors to be considered when a court is deciding whether to appoint counsel for an individual: (1) plaintiff’s ability to afford counsel, (2) plaintiff’s diligence in searching for counsel, (3) the merits of plaintiff’s case, and (4) plaintiff’s capacity to prepare and present the case without the aid of counsel. McCarthy v. Weinberg, 753 F.2d 836, 838-39 (10th Cir. 1985) (listing factors applicable to applications under the IFP statute); Castner v. Colorado Springs Cablevision, 979 F.2d 1417, 1421 (10th Cir. 1992). Thoughtful and prudent use of the appointment power is necessary so that willing counsel may be located without the need to make coercive appointments. The indiscriminate appointment of volunteer counsel to undeserving claims

will waste a precious resource and may discourage attorneys from donating their time. Castner, 979 F.2d at 1421. Under the first factor, the Court notes that it is recommending to the District Court that Plaintiff’s application to proceed in forma pauperis be denied. (See Doc. 9.) This weighs against the appointment of counsel. The second factor relates to Plaintiff’s diligence in searching for counsel. Plaintiff must show that he “made a reasonably diligent effort under the circumstances to obtain an attorney.” Martinez v. Pickering, No. 22-CV-4027-JWB-RES, 2022 WL 1604616, at *2 (D. Kan. May 20, 2022). Here, Plaintiff’s motion adequately establishes that he made the requisite effort to obtain an attorney, but has not been able to secure representation. (See generally Doc. 4.) This factor weighs in favor of the appointment of counsel.

The next factor is the viability of Plaintiff’s claims in federal court. See McCarthy, 753 F.2d at 838-39 (10th Cir. 1985); Castner, 979 F.2d at 1421. Based on the analysis in Section III, infra, the Court has serious concerns regarding the viability of Plaintiff’s claims in federal court. Regardless of the potential viability of Plaintiff’s claims, the final Castner factor will be determinative – Plaintiff’s capacity to prepare and present their case without the aid of counsel. 979 F.2d at 1420-21.

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Hyatt v. Owens, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hyatt-v-owens-ksd-2025.