Rademaker v. Ganzekaufer

CourtDistrict Court, S.D. California
DecidedJuly 10, 2023
Docket3:21-cv-01757
StatusUnknown

This text of Rademaker v. Ganzekaufer (Rademaker v. Ganzekaufer) 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
Rademaker v. Ganzekaufer, (S.D. Cal. 2023).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 DAVID RADEMAKER, Case No.: 3:21-cv-01757-AGS-AHG

12 Plaintiff, ORDER: 13 v. (1) DENYING PLAINTIFF’S 14 Katchua GANZEKAUFER, et al., MOTION TO APPOINT COUNSEL, 15 Defendants. and

16 (2) GRANTING PLAINTIFF’S 17 MOTION FOR EXTENSION OF TIME TO FILE AMENDED 18 COMPLAINT 19 [ECF No. 29] 20 21 22 23 24 25 26 Before the Court is Plaintiff David Rademaker’s (“Plaintiff”) Motion for 27 Appointment of Counsel and for Extension of Time. ECF No. 29. The Court will address 28 each request in turn. 1 I. PLAINTIFF’S MOTION FOR APPOINTMENT OF COUNSEL 2 Plaintiff, proceeding pro se, seeks to file a civil complaint pursuant to 42 U.S.C. § 3 1983 relating to incidents that occurred while incarcerated at Richard J. Donovan 4 Correctional Facility. ECF Nos. 14, 20, 25. On April 17, 2023, the Court dismissed 5 Plaintiff’s Second Amended Complaint for failure to state a claim upon which relief may 6 be granted, permitting him until August 4, 2023, to file a Third Amended Complaint that 7 cured the deficiencies noted. ECF Nos. 25, 28. On June 22, 2023, Plaintiff filed the instant 8 Motion for Appointment of Counsel. ECF No. 29. 9 A. Legal Standard 10 There is no constitutional right to appointment of counsel in a civil case, unless an 11 indigent litigant’s physical liberty is at stake. Lassiter v. Dep’t. of Soc. Servs., 452 U.S. 18, 12 25 (1981); see, e.g., United States v. Sardone, 94 F.3d 1233, 1236 (9th Cir. 1996) 13 (collecting cases to show that it is “well-established that there is generally no constitutional 14 right to counsel in civil cases”). Additionally, there is no constitutional right to a court- 15 appointed attorney in cases filed by inmates arising under 42 U.S.C. § 1983. Storseth v. 16 Spellman, 654 F.2d 1349, 1353 (9th Cir. 1981); see, e.g., Thornton v. Schwarzenegger, No. 17 10cv1583-BTM-RBB, 2011 WL 90320, at *1 (S.D. Cal. Jan. 11, 2011). 18 Nevertheless, courts have discretion to request legal representation for “any person 19 unable to afford counsel.” See 28 U.S.C. § 1915(e)(1); see also Terrell v. Brewer, 935 F.2d 20 1015, 1017 (9th Cir. 1991). Courts have required that plaintiffs demonstrate they are 21 indigent and that they have made a reasonably diligent effort to secure counsel before they 22 are eligible for an appointed attorney. Bailey v. Lawford, 835 F. Supp. 550, 552 (S.D. Cal. 23 1993) (extending the “reasonably diligent effort” standard used in Bradshaw v. Zoological 24 Soc’y of San Diego, 662 F.2d 1301, 1319 (9th Cir. 1981) to requests made pursuant to 28 25 U.S.C. § 1915); see, e.g., Verble v. United States, No. 07cv0472 BEN-BLM, 2008 WL 26 2156327, at *2 (S.D. Cal. May 22, 2008). 27 But even after a plaintiff satisfies the two initial requirements of indigence and a 28 diligent attempt to obtain counsel, “he is entitled to appointment of counsel only if he can 1 [also] show exceptional circumstances.” Bailey, 835 F. Supp. at 552 (citing Wilborn v. 2 Escalderon, 789 F.2d 1328, 1331 (9th Cir. 1986)). Finding exceptional circumstances 3 entails “an evaluation of both the ‘likelihood of success on the merits and the ability of the 4 plaintiff to articulate his claims pro se in light of the complexity of the legal issues 5 involved.’ Neither of these issues is dispositive and both must be viewed together before 6 reaching a decision.” Terrell, 935 F.2d at 1017 (quoting Wilborn, 789 F.2d at 1331); see 7 also Palmer v. Valdez, 560 F.3d 965, 970 (9th Cir. 2009). 8 B. Discussion 9 First, the Court examines the threshold requirements that Plaintiff is indigent and 10 has made a reasonably diligent effort to secure counsel. Here, the Court rejected Plaintiff’s 11 claim of indigence when it denied his motion to proceed in forma pauperis. ECF No. 14 at 12 3–4 (referencing “Plaintiff’s $533.86 in average monthly deposits, [and] average monthly 13 balance of $2,402.87 over the 6 months immediately preceding the filing of this action”). 14 Further, Plaintiff does not include any information in his motion about whether he has 15 attempted to secure counsel on his own. 16 Though Plaintiff did not satisfy the threshold requirements, for completeness, the 17 Court will briefly proceed to the next step of the analysis to determine whether Plaintiff 18 can show exceptional circumstances justifying court-appointed counsel by examining the 19 likelihood of Plaintiff succeeding on the merits and his ability to proceed without counsel. 20 1. Likelihood of Success on the Merits 21 “A plaintiff that provides no evidence of his likelihood for success at trial fails to 22 satisfy the first factor of the [exceptional circumstances] test.” Torbert v. Gore, No. 23 14cv2911-BEN-NLS, 2016 WL 1399230, at *1 (S.D. Cal. Apr. 8, 2016). Here, Plaintiff 24 has not offered evidence in his motion suggesting that he is likely to succeed on the merits.1 25 Additionally, there is little before the Court regarding the merits of Plaintiff’s case, other 26

27 1 That Plaintiff “feels he has a valid injury [and] civil rights claim,” (ECF No. 29 at 3), is 28 1 than assertions in the Second Amended Complaint, which was dismissed for failure to state 2 a claim upon which relief could be granted. See ECF No. 25. Thus, at this early stage of 3 the case, the Court cannot find that Plaintiff is likely to succeed on the merits. 4 2. Ability to Articulate Claims Pro Se 5 As to the second factor, Plaintiff cites barriers to successfully articulating his claims, 6 including limited access to the law library due to multiple transfers and his mental capacity. 7 ECF No. 29. However, Plaintiff fails to demonstrate an inability to represent himself 8 beyond the ordinary burdens encountered by incarcerated plaintiffs representing 9 themselves pro se. 10 First, limited access to the law library and unfamiliarity with the law are 11 circumstances common to most incarcerated plaintiffs and do not establish exceptional 12 circumstances. See, e.g., Wood v. Housewright, 900 F.2d 1332, 1335–36 (9th Cir. 1990) 13 (denying appointment of counsel where plaintiff complained that he had limited access to 14 law library and lacked a legal education); Galvan v. Fox, No. 2:15-CV-01798-KJM (DB), 15 2017 WL 1353754, at *8 (E.D. Cal. Apr. 12, 2017) (“Circumstances common to most 16 prisoners, such as lack of legal education and limited law library access, do not establish 17 exceptional circumstances that warrant a request for voluntary assistance of counsel”). 18 Second, though Plaintiff notes that his mental condition is progressing, which is 19 “affecting his daily activities” and causes him to “get[] confused easily,” (ECF No. 29 at 20 4), Plaintiff has not established that he is unable to prosecute this action. See ECF No.

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

Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Larry A. Storseth, 623435 v. John D. Spellman
654 F.2d 1349 (Ninth Circuit, 1981)
United States v. John Sardone
94 F.3d 1233 (Ninth Circuit, 1996)
Michael Lacey v. Joseph Arpaio
693 F.3d 896 (Ninth Circuit, 2012)
Palmer v. Valdez
560 F.3d 965 (Ninth Circuit, 2009)
Bailey v. Lawford
835 F. Supp. 550 (S.D. California, 1993)

Cite This Page — Counsel Stack

Bluebook (online)
Rademaker v. Ganzekaufer, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rademaker-v-ganzekaufer-casd-2023.