Sales v. Johnson

District Court, E.D. Wisconsin·Decided November 30, 2023·No. 2:23-cv-00397·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN ______________________________________________________________________________

ERIC D. SALES,

Plaintiff, v. Case No. 23-cv-397-pp

CLYDE JOHNSON,

Defendant. ______________________________________________________________________________

ORDER DENYING PLAINTIFF’S MOTION TO APPOINT COUNSEL (DKT. NO. 11), DENYING PLAINTIFF’S MOTION TO STRIKE (DKT. NO. 12) AND GRANTING DEFENDANT’S MOTION FOR LEAVE TO FILE AMENDED ANSWER (DKT. NO. 13) ______________________________________________________________________________

Plaintiff Eric D. Sales is proceeding on Eighth Amendment and state-law claims under 42 U.S.C. §1983. There are three motions pending: two from the plaintiff and one from the defendant. Dkt. Nos. 11–13. I. Plaintiff’s Motion to Appoint Counsel (Dkt. No. 11) The plaintiff asks the court to “appoint him a lawyer because he is incarcerated.” Dkt. No. 11 at ¶3. He says that “he is a layman in the areas of law,” his case is “overly complex” and “he is unable to present and articulate the facts of the matters pending without recruitment of counsel.” Id. at ¶10. He says he contacted at least three attorneys or firms to obtain counsel on his own, but they either declined or did not respond. Id. at ¶6. He attached letters from Quarles & Brady and the University of Wisconsin Law School, both of which declined to take his case. Dkt. No. 11-1. The plaintiff says he inarticulately conveyed “his current situation” to those legal offices, but he says that is because of “his lack of legal expertise.” Dkt. No. 11 at ¶8. The plaintiff’s motion includes, verbatim, two paragraphs from the legal standard that appears below. See id. at ¶¶3–5, 7, 9. This suggests that the plaintiff copied this language from a previous order issued by a court in the Eastern District of Wisconsin but did not identify the case from which that order came. Copying language without attributing it to its source is called “plagiarizing;” plagiarizing is an ethical violation and is prohibited in legal documents and pleadings. The court advises the plaintiff that he must provide a citation for all language that he takes from another source—whether it is from this court or a court in another jurisdiction or a non-court source—even if the language he quotes is an accurate statement of the law. 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 element, 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. In particular, the lawyers’ responses may have bearing on the court’s decision to exercise its discretion because they may shed light on whether the plaintiff’s attempts to hire counsel were reasonable. Pickett, 930 F.3d at 871. In deciding whether to recruit counsel, the court should consider the reasons the lawyer declined representation, including whether the plaintiff was unwilling (as opposed to unable) to pay a retainer; whether the lawyer lacked time or capacity to take on new clients; or whether the subject matter of the case requires a lawyer who specializes in a specific area of law. Id. The court should also consider how well the plaintiff articulated his case to the prospective lawyer. Id. Where a plaintiff “conveyed his situation well and counsel deemed the claim feeble, then it would be inappropriate for a court to intervene” and recruit counsel. Id. But, where a plaintiff is inarticulate, then a court “may have a useful role to play in recruiting counsel.” Id. “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 says he contacted at least three attorneys or firms and sought their help, and he attached responses from two that declined to take his case. Neither letter comments on the merits of the plaintiff’s case, and the plaintiff did not include copies of the letters that he sent to the firms asking them to represent him. He admits, however, that he was not able to articulate his need for counsel, which he says should weigh in favor of the court granting his motion. The court finds that the plaintiff’s efforts are sufficient to show he 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.

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