Mitchell v. Ryer

CourtDistrict Court, S.D. California
DecidedJune 16, 2025
Docket3:23-cv-00661
StatusUnknown

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

Bluebook
Mitchell v. Ryer, (S.D. Cal. 2025).

Opinion

2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 JOHN E. MITCHELL, Case No.: 23cv661-BJC (MSB)

12 Plaintiff, ORDER: 13 v. (1) DENYING MOTION TO APPOINT 14 M. RYER, et al., COUNSEL [ECF NO. 44]; 15 Defendants. (2) DENYING MOTION FOR A COURT 16 ORDER UNDER THE ALL WRITS ACT [ECF 17 NO. 35] 18 19 Plaintiff John E. Mitchell (“Plaintiff”) is incarcerated in state prison and proceeding 20 pro se and in forma pauperis in this civil rights action filed pursuant to 42 U.S.C. § 1983. 21 Now pending before the Court are Plaintiff’s Motion to Appoint Counsel [ECF No. 44] 22 and Motion for a Court Order Under the All Writs Act [ECF No. 35]. The Court addresses 23 each in turn. 24 I. MOTION TO APPOINT COUNSEL 25 On May 1, 2024, the Court denied Plaintiff’s first motion to appoint counsel, 26 finding Plaintiff failed to demonstrate a likelihood of success on the merits or that he 27 was unable to articulate his own claims. (See ECF No. 21 at 3–4.) On April 21, 2025, 2 appoint counsel (hereinafter “Motion”). See Bernhardt v. Los Angeles Cnty., 339 F.3d 3 920, 925 (9th Cir. 2003) (“Courts have a duty to construe pro se pleadings liberally, 4 including pro se motions as well as complaints.”). 5 In his single page Motion, Plaintiff raises concerns about “the invasion of privacy 6 and theft of documents that pertained to the merits of [this] case.” (ECF No. 44 at 1.) 7 He contends the theft of documents “leaves all other pending actions as contaminated 8 because I don’t know what else they took, what they read?” (Id.) Plaintiff says he does 9 not know the remedy for such a situation, which is why counsel must be appointed and 10 for “the integrity of my files/property.” (Id.) Plaintiff states “there is no lawful 11 explanation for the intrusion[s].” (Id.) The Motion does not contain further details 12 about which documents were allegedly stolen, nor does it explain what other “invasion 13 of privacy” may have occurred. (Id.) However, in a separate February 21, 2025, filing, 14 Plaintiff alleged that correctional officers searched his cell without his knowledge and 15 took an eyewitness declaration signed by inmate Juan Rosales, as well as other 16 eyewitness statements. (ECF No. 36 at 2–3.) 17 A. Legal Standard 18 The Constitution provides no right to appointment of counsel in a civil case unless 19 an indigent litigant may lose his physical liberty if he loses the litigation. Lassiter v. 20 Dep’t Soc. Servs., 452 U.S. 18, 25 (1981); Palmer v. Valdez, 560 F.3d 965, 970 (9th Cir. 21 2009). Additionally, there is no constitutional right to a court-appointed attorney in 22 cases filed by inmates arising under 42 U.S.C. § 1983. Storseth v. Spellman, 654 F.2d 23 1349, 1353 (9th Cir. 1981). While 28 U.S.C. § 1915(e)(1) gives district courts discretion 24 to “request” that an attorney represent indigent civil litigants, it may only be exercised 25 upon a showing of “exceptional circumstances.” Agyeman v. Corr. Corp. Am., 390 F.3d 26 1101, 1103 (9th Cir. 2004); Terrell v. Brewer, 935 F.2d 1015, 1017 (9th Cir. 1991). When

27 assessing whether exceptional circumstances exist, the Court must undergo “an 2 involved.’” Wilborn v. Escalderon, 789 F.2d 1328, 1331 (9th Cir. 1986) (quoting 3 Weygandt v. Look, 718 F.2d 952, 954 (9th Cir. 1983)). Courts must review both factors 4 before deciding whether to appoint counsel, and neither factor is individually 5 dispositive. Id. 6 B. Analysis 7 a. Likelihood of Success on the Merits 8 First, Plaintiff has not shown he is likely to succeed on the merits at this stage in 9 the proceedings. See Bailey v. Lawford, 835 F. Supp. 550, 552 (S.D. Cal. 1993) (finding 10 that where the plaintiff offered “no evidence other than his own assertions to support 11 his claims,” he failed to satisfy the first Wilborn factor). Though the Court found 12 Plaintiff’s First Amended Complaint (“FAC”) raised cognizable constitutional claims 13 against various California Department of Corrections and Rehabilitation (“CDCR”) 14 employees [ECF No. 7], it is still premature to determine the strength of these claims. 15 See e.g., Arellano v. Blahnik, No. 16cv2412-CAB-RNB, 2018 WL 4599697, at *2 n.1 (S.D. 16 Cal. Sept. 25, 2018) (denying motion to appoint counsel because “[a]lthough plaintiff’s [ 17 ] claim survived defendant’s motion to dismiss, it is still too early to determine the 18 likelihood of success on the merits.”); Hearn v. RJD Warden, No. 22cv255-TWR-DDL, 19 2022 WL 17407996, at *2 (S.D. Cal. Dec. 2, 2022) (when the plaintiff’s claims remain 20 unproven at early stages of proceedings, “there is no basis upon which the Court can 21 predict Plaintiff’s success at trial.”). 22 Since his initial April 2024 motion to appoint counsel, Plaintiff has not provided 23 any new evidence demonstrating he is likely to be successful on the merits. (Compare 24 ECF No. 21, with ECF No. 44.) The instant Motion merely makes general allegations 25 about the invasion of privacy and theft of documents, without explaining why Plaintiff is 26 likely to prevail in this lawsuit. (See ECF No 44 at 1.) Therefore, Plaintiff fails to satisfy

27 the first factor of the Wilborn test. See, e.g., Bailey v. Lawford, 835 F. Supp. 550, 552 2 assertions to support his claims,” he failed to satisfy the first Wilborn factor). 3 b. Plaintiff’s Ability to Articulate Claims 4 Second, Plaintiff has not established that this case is “exceptional” or that the 5 issues in it are particularly complex. In the instant Motion, Plaintiff asks for 6 appointment of counsel to protect the “integrity of my files/property.” (ECF No. 44 at 7 1.) However, he does not explain why counsel is needed considering the complexity of 8 the legal issues involved in this case, as required by the Wilborn test. See 789 F.2d at 9 1331. In addition to the filings currently before the Court, Plaintiff has filed various 10 pleadings including a First Amended Complaint [ECF No. 6], Requests for a Stay of 11 Proceedings [ECF Nos. 9 & 10], a Motion to Appoint Counsel [ECF No. 20], and various 12 Requests for Judicial Notice [ECF Nos. 36, 39–41]. Plaintiff also appeared by video at 13 settlement conferences on January 24, 2025; March 10, 2025; and April 22, 2025, and 14 represented himself admirably during those sessions. (ECF Nos. 32, 37, 42.) To date, 15 Plaintiff has demonstrated a good grasp of basic litigation procedure and has articulated 16 his claims adequately. See Palmer v. Valdez, 560 F.3d 965, 970 (9th Cir. 2009) (finding 17 that the second Wilborn factor was not satisfied where the District Court observed 18 Plaintiff “was well-organized, made clear points, and presented evidence effectively”). 19 Other factors like indigency, incarceration, and being untrained in the law are 20 difficulties that any imprisoned litigant would have in proceeding pro se; although the 21 Court is sympathetic to these circumstances, they are not exceptional factors. See 22 Wood v.

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Bluebook (online)
Mitchell v. Ryer, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mitchell-v-ryer-casd-2025.