Marks v. State of Nevada

CourtDistrict Court, D. Nevada
DecidedFebruary 1, 2022
Docket2:18-cv-01421
StatusUnknown

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

Bluebook
Marks v. State of Nevada, (D. Nev. 2022).

Opinion

2 UNITED STATES DISTRICT COURT 3 DISTRICT OF NEVADA 4 * * * 5 Louis Marks, Case No. 2:18-cv-01421-RFB-BNW 6 Plaintiff, 7 ORDER re ECF No. 50 v. 8 State of Nevada, et al., 9 Defendants. 10 11 12 Presently before the Court is pro se plaintiff Louis Mark’s second1 motion for 13 appointment of counsel (ECF No. 50), filed on November 18, 2021. Defendant Vincent Lorenz 14 opposed at ECF No. 54. Plaintiff did not file a reply. The Court held a hearing via Zoom video 15 conference on February 1, 2022, where Plaintiff and Defendant were both present. 16 Plaintiff moves under both 28 U.S.C. § 1915(e)(1) and 28 U.S.C. 2254(h) to argue that 17 appointment of counsel is appropriate in this case. But the Court construes Plaintiff’s request 18 proper only under only 28 U.S.C. § 1915(e)(1), as this case does not relate to a federal habeas 19 corpus proceeding but, rather, a § 1983 claim. 20 I. Background 21 Mr. Marks, who is currently in custody at Southern Desert Correctional Center (“SDCC”), 22 alleges an Eighth Amendment unsafe prison conditions claim. ECF No. 7 at 4–6. More 23 specifically, he alleges that Defendant learned on at least two occasions, including from a unit 24 officer, that a table at the SDCC facility was unbolted and broken. Id. at 4, 9–10. But despite 25 knowing of this allegedly unsafe condition, Defendant failed to provide any warnings to others 26 1 Plaintiff first moved for appointment of counsel at the same time that he initiated this case in July of 27 2018. See ECF No. 2. The Hon. Judge Boulware denied Mr. Marks’ motion without prejudice, noting that the court did not “find exceptional circumstances that warrant the appointment of counsel.” ECF No. 11 at 1 regarding this alleged defect. Id. at 4. As a result, Plaintiff alleges that he unknowingly sat on the 2 broken table and seriously injured his hip, pelvis, and back. Id. 3 Mr. Marks now requests a court-appointed attorney, arguing that he is unable to afford 4 counsel, the “substantive issues and procedural matters in this case are too complex[,]” and he is 5 unable to investigate and complete other discovery, including taking depositions, because he is 6 incarcerated. ECF No. 50 at 1-2. He also notes that his “sentence structure is ____[,]” which the 7 Court understands to mean that Plaintiff has a basic grasp of writing. Id. at 2. 8 Additionally, Plaintiff contends that appointing counsel would not only help him in 9 presenting and litigating his case, but it also would help more efficiently facilitate proceedings. 10 Id. 11 Finally, Plaintiff argues that the “ends of justice would best be served” if counsel is 12 appointed. Id. 13 Defendant opposes Mr. Marks’ request. He argues that Plaintiff does not have a 14 constitutional right to counsel to litigate a § 1983 claim; Plaintiff has not shown an inability to 15 articulate his claims without counsel, as previous filings are “cogent and well-articulated with 16 respect to both the law and facts[;]” Plaintiff’s case is not complex enough to require counsel; and 17 Plaintiff has not demonstrated that he is likely to succeed on the merits. ECF No. 54 at 1–3. 18 Defendant further notes that a court may not appoint counsel to aid a plaintiff with discovery. Id. 19 at 2. Finally, he argues that Plaintiff’s reasons for seeking appointment of counsel do not 20 constitute “the type of special circumstances that warran[t] appointment of counsel.” Id. 21 II. Discussion 22 Civil litigants do not have a Sixth Amendment right to appointed counsel. Storseth v. 23 Spellman, 654 F.2d 1349, 1353 (9th Cir. 1981). In very limited circumstances, federal courts are 24 empowered to request an attorney to represent an indigent civil litigant. For example, courts have 25 discretion, under 28 U.S.C. § 1915(e)(1), to “request” that an attorney represent indigent civil 26 litigants upon a showing of “exceptional circumstances.” Agyeman v. Corrections Corp. of Am., 27 390 F.3d 1101, 1103 (9th Cir. 2004). 1 To determine whether the “exceptional circumstances” necessary for appointment of 2 counsel are present, the court evaluates (1) the likelihood of plaintiff’s success on the merits and 3 (2) the plaintiff’s ability to articulate his claim pro se “in light of the complexity of the legal 4 issues involved.” Agyeman, 390 F.3d at 1103 (quoting Wilborn, 789 F.2d at 1331). A court may 5 find that “exceptional circumstances” exist if a claim is either factually or legally complex. See, 6 e.g., McElyea v. Babbitt, 833 F.2d 196, 200 n.3 (9th Cir. 1987) (per curiam) (suggesting that a 7 plaintiff’s claim concerning the provision of religious books in prison raises “complicated 8 constitutional issues”). 9 Neither of these factors is dispositive and both must be viewed together. Wilborn, 789 10 F.2d at 1331. It is within the court’s discretion whether to request that an attorney represent an 11 indigent civil litigant under 28 U.S.C. § 1915(e)(1). Palmer v. Valdez, 560 F.3d 965, 970 (9th Cir. 12 2009). 13 A. Whether Mr. Marks’ claim has a likelihood of success on the merit 14 Here, Mr. Marks’ Eighth-Amendment claim has a likelihood of success on the merits. 15 This is because he pled two claims in his complaint (i.e., deliberate indifference to unsafe prison 16 conditions and deliberate indifference to serious medical needs) and one—deliberate indifference 17 to unsafe prison conditions—survived the Court’s screening process. ECF No. 11 at 5. The Hon. 18 Judge Boulware subsequently affirmed the screening order in response to Defendant’s motion to 19 dismiss. See ECF No. 45 (“The Motion to Dismiss [at ECF No. 25] is DENIED in part and 20 GRANTED in part. The Court denies the Motion to the exten[t] it seeks dismissal of the Eighth 21 Amendment claim that the Court permitted to proceed pursuant to its Screening Order [at ECF 22 No. 11]. This claim shall proceed for the same reasons identified in the Order [at ECF No. 11]. 23 The Court grants the Motion as to the dismissal of the monetary damages claim against Defendant 24 Lorenz in his official capacity. Fowler v. Guerin, 918 F.3d 644, 647 (9th Cir. 2019).”). 25 “The Ninth Circuit has indicated that the articulation of a cognizable claim for relief may 26 itself be sufficient to satisfy the ‘merit’ analysis on a motion for appointment of counsel.” Turner 27 v. Riaz, No. 216CV0969MCEACP, 2018 WL 5962726, at *4 (E.D. Cal. Nov. 14, 2018). This 1 Of note, Defendant argued at the motion hearing that Plaintiff’s claim or theory of the 2 case has changed, and this change cuts against his likelihood of success on the merits. While the 3 Court finds that it is the screening order that controls for purposes of determining whether 4 Plaintiff has a likelihood of success on the merits, it will, nonetheless, address Defendant’s 5 argument. 6 According to Defendant, Plaintiff’s complaint alleges that Plaintiff sustained serious 7 injuries because the table had no bolts whereas in his motion to appoint an expert witness (at ECF 8 No. 41), Plaintiff suggests that he was injured because the table had the wrong bolts.

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