DeLaurence Robinson v. Dale Scrogum, 876 F.3d 923

Robinson, an Illinois inmate, sued five Pontiac Correctional Center guards under 42 U.S.C. § 1983 alleging they beat him in 2011 in retaliation for filing grievances and used excessive force, with racial taunts during the assault.
A prison disciplinary committee found Robinson guilty of attempted assault on staff, revoking good-time credits and imposing segregation; the committee found he jerked away, refused to walk, and attempted to bite and spit.
Robinson filed claims for retaliation, excessive force, and equal protection; the district court dismissed the equal-protection claim and later granted summary judgment dismissing the remainder, reasoning Edwards v. Balisok barred the suit because some allegations conflicted with the disciplinary finding.
Robinson repeatedly requested recruitment of counsel, citing an eighth-grade education, heavy psychiatric medication, and reliance on a fellow inmate to draft filings; the district court denied counsel, saying Robinson demonstrated capacity to litigate from his filings.
The Seventh Circuit found the district court erred in denying counsel because it relied on Robinson’s filings without addressing that another inmate assisted him, and that counsel likely could have helped amend claims to avoid the Edwards bar.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Edwards/Heck bars Robinson’s § 1983 claims	Robinson says excessive force and retaliation claims can proceed because he was not resisting and was victim of an unprovoked attack	Defendants argue the disciplinary conviction for attempted assault contradicts Robinson’s allegations and therefore Edwards bars his suit	Court did not resolve merits on appeal; noted counsel could have framed claims to avoid Edwards bar
Whether district court abused discretion by denying recruited counsel	Robinson argues limited education, heavy medication, and reliance on jailhouse lawyer justify counsel recruitment	Defendants implicitly argue Robinson can proceed pro se because his filings show ability to present the case	Seventh Circuit held denial was abuse of discretion because court relied on filings without recognizing inmate assistance and counsel likely would have helped
Whether Robinson made reasonable efforts to obtain counsel	Robinson showed efforts to find counsel and requested recruitment	Defendants contest not directly; district court found efforts reasonable	Appellate court accepted that Robinson made reasonable efforts
Whether lack of counsel prejudiced Robinson’s case	Robinson contends counsel would have avoided procedural pitfalls (Edwards) and better framed claims	Defendants argue pro se filings were adequate	Seventh Circuit found reasonable likelihood counsel would have altered outcome; prejudice shown

Edwards v. Balisok, 520 U.S. 641 (1997) (extends Heck favorable-termination bar to prison disciplinary challenges)
Heck v. Humphrey, 512 U.S. 477 (1994) (plaintiff cannot seek damages that would imply invalidity of an outstanding conviction)
Pruitt v. Mote, 503 F.3d 647 (7th Cir. 2007) (standard for recruiting counsel for indigent pro se civil litigants)
Diggs v. Ghosh, 850 F.3d 905 (7th Cir. 2017) (requests for counsel require careful consideration)
Dewitt v. Corizon, Inc., 760 F.3d 654 (7th Cir. 2014) (court should consider pro se litigant’s limitations when deciding to recruit counsel)
Henderson v. Ghosh, 755 F.3d 559 (7th Cir. 2014) (assistance from fellow inmates should not weigh against recruiting counsel)
Davis v. Moroney, 857 F.3d 748 (7th Cir. 2017) (intellectual disabilities and low literacy weigh in favor of recruiting counsel)
Navejar v. Iyiola, 718 F.3d 692 (7th Cir. 2013) (permitting amendment to avoid Edwards bar where plausible)
Santiago v. Walls, 599 F.3d 749 (7th Cir. 2010) (prejudice from denial of counsel requires reasonable likelihood counsel would have changed outcome)