Saffold v. Fuller

CourtDistrict Court, E.D. Wisconsin
DecidedMay 16, 2025
Docket2:22-cv-01467
StatusUnknown

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

Bluebook
Saffold v. Fuller, (E.D. Wis. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN ______________________________________________________________________________

CLARENCE ALBERT SAFFOLD, III,

Plaintiff, v. Case No. 22-cv-1467-pp

DR. RICHARD FULLER, et al.,

Defendants. ______________________________________________________________________________

ORDER DENYING WITHOUT PREJUDICE PLAINTIFF’S MOTION TO APPOINT COUNSEL (DKT. NO. 60) _____________________________________________________________________________

Plaintiff Clarence Albert Saffold, III, who is representing himself, is proceeding under 42 U.S.C. §1983 on claims under federal and state law. On April 3, 2025, the court received from the plaintiff a motion asking the court to recruit counsel to represent him in this lawsuit. Dkt. No. 60. The plaintiff asserts that he is unable to afford counsel, the issues in his case are complex and he has limited legal knowledge. Id. at 1. He says that he reached out to three attorneys asking them to assist him, but that none of the attorneys responded. Id. The plaintiff attached to a declaration he submitted in support of his motion copies of letters to the three attorneys. Dkt. No. 62-1. The declaration reiterates the plaintiff’s stated reasons for the court to recruit him counsel. Dkt. No. 62. The plaintiff adds that he was working with a jailhouse attorney, but says that he now is at a different institution and no longer can work with that person. Id. at ¶5. He suggests that he has had discussions with defense counsel about settling this matter, and he asks for an attorney to help him with future mediation proceedings. Id. at ¶6. The plaintiff says that he has “never litigated a civil matter” and has no trial experience. Id. at ¶8. He says that he would need help obtaining expert witnesses and opposing defendant’s arguments in opposition to his claims. Id. at ¶¶7, 9. In a civil case, the court has the discretion to recruit counsel for individuals unable to afford counsel. Navejar v. Iyola, 718 F.3d 692, 696 (7th Cir. 2013); 28 U.S.C. §1915(e)(1); Ray v. Wexford Health Sources, Inc., 706 F.3d 864, 866–67 (7th Cir. 2013). “[D]eciding whether to recruit counsel ‘is a difficult decision: Almost everyone would benefit from having a lawyer, but there are too many indigent litigants and too few lawyers willing and able to volunteer for these cases.’” Henderson v. Ghosh, 755 F.3d 559, 564 (7th Cir. 2014) (quoting Olson v. Morgan, 750 F.3d 708, 711 (7th Cir. 2014)). In exercising its discretion, the court must consider two things: “(1) ‘has the indigent plaintiff made a reasonable attempt to obtain counsel or been effectively precluded from doing so,’ and (2) ‘given the difficulty of the case, does the plaintiff appear competent to litigate it himself?’” Eagan v. Dempsey, 987 F.3d 667, 682 (7th Cir. 2021) (quoting Pruitt v. Mote, 503 F.3d 647, 654–55 (7th Cir. 2007)). To satisfy the first prong, the court must determine that a plaintiff made a good faith effort to hire counsel. Pickett v. Chi. Transit Auth., 930 F.3d 869, 871 (7th Cir. 2019). “This is a mandatory, threshold inquiry that must be determined before moving to the second inquiry.” Eagan, 987 F.3d at 682. To do so, the plaintiff must show he contacted at least three lawyers and provide the court with (1) the lawyers’ names; (2) their addresses; (3) how and when the plaintiff attempted to contact the lawyer; and (4) the lawyers’ responses. “The second inquiry requires consideration of both the factual and legal complexity of the plaintiff’s claims and the competence of the plaintiff to litigate those claims.” Eagan, 987 F.3d at 682. When considering the second prong, the court “must examine the difficulty of litigating specific claims and the plaintiff’s individual competence to litigate those claims without counsel.” Pennewell v. Parish, 923 F.3d 486, 490 (7th Cir. 2019). The court looks at “whether the difficulty of the case, factually, legally, and practically, exceeds the litigant’s capacity as a layperson to coherently litigate the case.” Id. This includes “all tasks that normally attend litigation,” such as “evidence gathering, preparing and responding to court filings and motions, navigating discovery, and putting on a trial.” Id. at 490–91. The court “must consider the plaintiff’s literacy, communication skills, education level, litigation experience, intellectual capacity, psychological history, physical limitations and any other characteristics that may limit the plaintiff’s ability to litigate the case.” Id. at 491. In situations where the plaintiff files his motion in the early stages of the case, the court may determine that it is “impossible to tell whether [the plaintiff] could represent himself adequately.” Pickett, 930 F.3d at 871. The plaintiff has satisfied the first Pruitt inquiry. He attached letters that he sent to multiple attorneys or firms about representing him in this case, and he says that none of those attorneys or firms responded to his request. These efforts show that the plaintiff sufficiently attempted to obtain a lawyer on his own before asking for the court’s assistance. But the plaintiff has not satisfied the second Pruitt inquiry. The court first observes that although the plaintiff says he never has litigated a civil matter, he previously litigated Case No. 19-cv-1414-pp before this court. The plaintiff twice asked the court to recruit him an attorney in that case, too. Case No. 19-cv-1414-pp, Dkt. Nos. 9, 112. In denying the second motion, the court stated that [t]he plaintiff’s detailed filings show that he has a continued understanding of the legal issues in his case and the ability to competently research and present his position on those issues. The plaintiff further demonstrated his above-average sophistication during the April 27, 2022 evidentiary hearing on the defendants’ motion for summary judgment on exhaustion grounds. The plaintiff effectively presented his position on the issues and succeeded in defeating summary judgment as to some of the defendants. The court understands that the plaintiff has limited legal knowledge and no formal legal training. But the same is true of nearly all civil litigants who represent themselves, particularly those who are incarcerated. As the court previously noted, “‘there are too many indigent litigants and too few lawyers willing and able to volunteer for these cases.’” The plaintiff has not shown that he is one of those litigants most in need of an attorney.

Id., Dkt. No. 122 at 3 (internal citations omitted). The court’s analysis of the plaintiff’s litigation abilities has not changed since he filed this case. The plaintiff filed a very detailed, organized and articulate complaint that laid out his meticulous allegations against the defendants. Dkt. No. 1. As in his previous case, his complaint shows that he “understands the issues involved in his case, knows the details relevant to presenting and proving his claims and comprehends his role at this point in the litigation.” Case No. 19-cv-1414-pp, Dkt. No.

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Related

Ray v. Wexford Health Sources, Inc.
706 F.3d 864 (Seventh Circuit, 2013)
Pruitt v. Mote
503 F.3d 647 (Seventh Circuit, 2007)
Ladell Henderson v. Parthasarathi Ghosh
755 F.3d 559 (Seventh Circuit, 2014)
Jeffrey Olson v. Donald Morgan
750 F.3d 708 (Seventh Circuit, 2014)
Eduardo Navejar v. Akinola Iyiola
718 F.3d 692 (Seventh Circuit, 2013)
James Pennewell v. James Parish
923 F.3d 486 (Seventh Circuit, 2019)
Pickett v. Chi. Transit Auth.
930 F.3d 869 (Seventh Circuit, 2019)
Shawn Eagan v. Michael Dempsey
987 F.3d 667 (Seventh Circuit, 2021)

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Bluebook (online)
Saffold v. Fuller, Counsel Stack Legal Research, https://law.counselstack.com/opinion/saffold-v-fuller-wied-2025.