Ekeh v. Butler County District Court, 5:25-cv-04063

Anthony Ekeh filed a civil complaint against Budget Truck Rental LLC, Butler County District Court, and seven individuals, stemming from his October 2024 arrest on state charges in Kansas.
Ekeh sought the appointment of counsel to represent him, claiming inability to afford one.
In civil cases, unlike criminal proceedings, there is no automatic right to court-appointed counsel; such decisions are discretionary.
The court considers several factors for appointment, including the plaintiff’s financial status, efforts to obtain counsel, merits of the claim, and ability to self-represent.
Ekeh was allowed to proceed in forma pauperis, but service of the complaint was stayed pending preliminary screening due to concerns over the merits of his case and similarities to prior dismissed actions.
The court found Ekeh’s efforts to secure counsel inadequate, as his contacts were mostly out-of-state and predated the events giving rise to this suit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Appointment of Counsel	Ekeh cannot afford counsel and needs legal representation	No automatic right to counsel in civil cases; plaintiff did not meet required diligence or merit thresholds	Motion for appointment of counsel denied

Castner v. Colo. Springs Cablevision, 979 F.2d 1417 (10th Cir. 1992) (establishes factors for discretionary appointment of counsel in civil cases)