Hymas v. United States Department of State

CourtDistrict Court, E.D. Tennessee
DecidedApril 17, 2025
Docket3:23-cv-00336
StatusUnknown

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

Bluebook
Hymas v. United States Department of State, (E.D. Tenn. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT KNOXVILLE

JAY HYMAS, ) ) Plaintiff, ) ) v. ) No. 3:23-CV-00336-DCLC-JEM ) UNITED STATES DEPARTMENT OF STATE ) and UNITED STATES DEPARTMENT OF THE ) TREASURY, ) ) Defendants. )

MEMORANDUM OPINION AND ORDER

This matter is before the Court on Plaintiff Jay Hymas’s Motion for Appointment of Counsel Per Rule 23 [Doc. 38] and Defendants’ Response in Opposition [Doc. 40]. During the coronavirus pandemic in 2020, Mr. Hymas was in South America, where the virus’s outbreak had prompted the cancellation of his commercial flight back to the United States. [Compl., Doc. 1, at 5]. He then contacted the United States Embassy and, through the United States Department of State, secured an evacuation flight to the United States. [Id.]. He is now upset about the bill that he received for that flight, which he claims is “10 times the amount of what a ‘full-fare economy flight’ . . . was at the time,” and in response to his non-payment of that bill, the Department of State allegedly put a “hold” on his passport, which he has since been unable to renew. [Id.]. Acting pro se, Mr. Hymas has now filed suit against the Department of State and the Department of the Treasury, bringing claims for extortion, violation of his constitutional right of his “liberty to travel,” violation of his constitutional right to due process, and violation of the Administrative Procedure Act, 5 U.S.C. § 551 et seq. [Id. at 4–5]. He requests class certification of these claims under Federal Rule of Civil Procedure 23, “believ[ing] that many thousands if not tens of thousands of other citizens of the United States suffered the same fate” as he did. [Id. at 5]. To assist him in pursuing class certification, he now moves the Court for the appointment of counsel under Rule 23(g)(3), which provides that “[t]he court may designate interim counsel

to act on behalf of a putative class before determining whether to certify the action as a class action.” (emphasis added); see Smith v. FirstEnergy Corp., No. 2:20-cv-03755, No. 2:20-cv- 03987, No. 2:20-cv-03954, 2021 WL 9032912, at *1 (S.D. Ohio May 13, 2021) (observing that “Rule 23(g)(3) gives a district court discretion”). The appointment of counsel in a civil case is “a privilege,” Lavado v. Keohane, 992 F.2d 601, 606 (6th Cir. 1993) (citation omitted), because a litigant in a civil case has no constitutional right to counsel, Shepherd v. Wellman, 313 F.3d 963, 970 (6th Cir. 2002). Mr. Hymas, therefore, must establish that exceptional circumstances warrant the appointment of counsel. See Lanier v. Bryant, 332 F.3d 999, 1006 (6th Cir. 2003) (“The appointment of counsel in a civil proceeding . . . is justified only in exceptional circumstances.” (emphasis

added) (citation omitted))); Brubaker v. Barrett, 801 F. Supp. 2d 743, 763 (E.D. Tenn. 2011) (“It is [the movant’s] burden to show that ‘exceptional circumstances’ exist.”). To show that exceptional circumstances exist and warrant the appointment of counsel, Mr. Hymas must address “the type of case and [his] abilities . . . to represent himself,” which requires the Court to consider certain factors: “the ‘complexity of the factual and legal issues involved,’” “the nature of the case,” and “[Mr. Hymas’s] ability to prosecute the case in a pro se capacity,” Shavers v. Bergh, 516 F. App’x 568, 571 (6th Cir. 2013) (quoting Lavado, 992 F.2d at 606). Defendants maintain that Mr. Hymas fails to demonstrate that exceptional circumstances exist under these factors. [Defs.’ Resp. at 1]. Although Mr. Hymas does not expressly cite these factors in arguing that he is entitled to counsel, the Court, in deference to his pro se status, will endeavor to view his arguments through the prism of these factors. See Urbina v. Thoms, 270 F.3d 292, 295 (6th Cir. 2001) (recognizing that a pro se litigant’s “pleadings are held to a less stringent standard than those prepared by an attorney” (citations

omitted)). In moving for counsel, Mr. Hymas raises a twofold argument. First, he argues that he “is not an attorney,” [Pl.’s Mot. at 1], but if the Court were to accept this argument, it would have to appoint counsel to all pro se parties because of their pro se status. This argument runs crosswise with case law—namely, the case-specific factors that Mr. Hymas must satisfy—and without some explanation as to why this case is especially complex legally or factually, Mr. Hymas’s pro se standing is not an exceptional circumstance that justifies the appointment of counsel on his behalf. See United States v. Rolon, No. 22-10970, 2022 WL 16959204, at *1 (11th Cir. Nov. 16, 2022) (“[P]ro se status alone and lack of legal knowledge d[o] not establish that appointment of counsel is necessary. Rather, appointment of counsel in this context is ‘a

privilege justified only be exceptional circumstances, such as the presence of facts or legal issues so novel as to require the assistance of a trained practitioner.’” (quoting Kilgo v. Ricks, 983 F.2d 189, 193 (11th Cir. 1993)); see generally Cavin v. Mich. Dep’t of Corrs., 927 F.3d 455, 461 (6th Cir. 2019) (“It is the rare civil case in which a court must provide a party an attorney, and only ‘exceptional circumstances’ require deviating from this rule.”). And even without the assistance of counsel, Mr. Hymas, apart from some initial difficulty with effecting service of process, has ably represented himself to date. He has, for instance, demonstrated a command for the Court’s local rules, see [Pl.’s Notice of Violation of Court Rules, Doc. 15], and some aptitude for motion practice, see [Pl.’s Mot. for Default J., Doc. 17; Pl.’s Mot. for Recusal, Doc. 29; Pl.’s Mot. for Recons., Doc. 30; Pl.’s Mot. for Appointment of Counsel, Doc. 38; Pl.’s Mot. for Extension of Time, Doc. 39]. Second, Mr. Hymas argues that he requires the appointment of counsel because “it is improper” for him to make “legal arguments that implicate the interests of the class.” [Pl.’s Mot.

at 1]. Mr. Hymas is correct in arguing that he cannot make arguments on behalf of a putative class; after all, as a pro se litigant, he cannot appear pro se on behalf of anyone but himself, much less on behalf of a class. See Fymbo v. State Farm Fire & Cas. Co., 213 F.3d 1320, 1321 (10th Cir. 2000) (“A litigant may bring his own claims to federal court without counsel, but not the claims of others.” (citing 28 U.S.C. § 1654)); Cohen v. Att’y Gen. of Mass., No. CA 11-115- NMG, 2011 WL 5008088, at *7 (D. Mass Oct. 18, 2011) (“Although 28 U.S.C. § 1654 permits persons to proceed pro se, this provision does not allow unlicenced [sic] lay people to represent other pro se litigants.” (citation omitted)); Powers v. NWA, Inc., No. 05-2468-B/P, 2006 WL 984738, at *2 (W.D. Tenn. Apr.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Fymbo v. State Farm Fire & Casualty Co.
213 F.3d 1320 (Tenth Circuit, 2000)
Milburn L. Edwards v. Lt. L.A. Simpson
833 F.2d 1012 (Sixth Circuit, 1987)
Henry Lavado, Jr. v. Patrick W. Keohane
992 F.2d 601 (Sixth Circuit, 1993)
Benjamin Urbina v. Maryellen Thoms, Warden
270 F.3d 292 (Sixth Circuit, 2001)
Bill Wayne Shepherd v. Billy Wellman
313 F.3d 963 (Sixth Circuit, 2002)
David W. Lanier v. Ed Bryant
332 F.3d 999 (Sixth Circuit, 2003)
Michael Shavers v. David Bergh
516 F. App'x 568 (Sixth Circuit, 2013)
United States v. Mosley
779 F. Supp. 2d 398 (D. New Jersey, 2011)
Brubaker v. Barrett
801 F. Supp. 2d 743 (E.D. Tennessee, 2011)
Darrell Debrew v. Atwood
792 F.3d 118 (D.C. Circuit, 2015)
Lamont Heard v. Patricia Caruso
351 F. App'x 1 (Sixth Circuit, 2009)
Joshua Howard v. William Pollard
814 F.3d 476 (Seventh Circuit, 2015)
Mario Cavin v. Mich. Dep't of Corr.
927 F.3d 455 (Sixth Circuit, 2019)
Palasty v. Hawk
15 F. App'x 197 (Sixth Circuit, 2001)
Gamboa v. Ford Motor Co.
381 F. Supp. 3d 853 (E.D. Michigan, 2019)
Ziegler v. Michigan
90 F. App'x 808 (Sixth Circuit, 2004)
Oxendine v. Williams
509 F.2d 1405 (Fourth Circuit, 1975)
Kilgo v. Ricks
983 F.2d 189 (Eleventh Circuit, 1993)

Cite This Page — Counsel Stack

Bluebook (online)
Hymas v. United States Department of State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hymas-v-united-states-department-of-state-tned-2025.