Fredrick Walker v. Timothy Price, 900 F.3d 933

Background

Walker, an Illinois maximum-security inmate, sued prison officers under 42 U.S.C. § 1983 for excessive force and denial of medical care after an alleged assault during a cell transfer.
Walker repeatedly requested the court recruit pro bono counsel; the magistrate and district courts denied the first five requests, finding his claims simple and his pretrial filings competent (often prepared with help from a jailhouse lawyer, Minter).
The court later scheduled a jury trial to be conducted by videoconference due to security concerns; between the denials and trial, Minter was transferred and Walker lost his informal assistance.
Walker filed a sixth motion to recruit counsel prior to the video jury trial; the district court denied it, again citing his prior filings and video status hearings as evidence of competence.
The video trial proceeded with technological hiccups; Walker performed poorly in witness examination and the jury returned a verdict for defendants.
The Seventh Circuit vacated and remanded, holding the district court abused its discretion by denying Walker’s sixth request because the video jury trial and loss of his jailhouse assistance materially changed the Prui tt analysis and likely prejudiced him.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred in denying motion to recruit counsel under 28 U.S.C. § 1915(e)(1) / Pruitt factors	Walker: his cognitive limitations, loss of jailhouse lawyer, impending jury trial by videoconference made him incompetent to proceed pro se	Court/Defs: claims were simple; Walker’s prior pro se filings and video status hearing appearances showed competence	Court abused discretion as to the sixth motion — video jury trial and loss of assistance changed the calculus and court failed to assess Walker’s ability to handle a video trial
Whether a videoconference jury trial was improper	Walker: video trial impedes access and weakens ability to present credibility-based case	Defs: security, cost, and safety justified video trial; claims were simple so little prejudice	Court did not decide whether video trial itself was an abuse; error was failure to assess Walker’s capacity to litigate a video trial when denying counsel request
Whether denial of counsel prejudiced Walker's trial outcome	Walker: absent counsel, he performed ineffectively at trial (poor witness examination, foundational issues, technological problems)	Defs: Walker’s coherent opening and prior filings show lack of prejudice	Held prejudiced — reasonable likelihood counsel would have improved presentation and affected outcome
Whether district court could rely on prior pretrial performance and jailhouse assistance	Walker: earlier filings reflected Minter’s help; the court should reassess competence when that assistance ceased	Court/Defs: prior filings and status-hearing conduct indicate competence	Held error — court over-relied on filings made with jailhouse assistance and on limited status-hearing appearances; needed fresh evaluation before denying sixth request

Key Cases Cited

Pruitt v. Mote, 503 F.3d 647 (7th Cir. 2007) (sets two-step standard for recruiting counsel under § 1915(e)(1))
Perez v. Fenoglio, 792 F.3d 768 (7th Cir. 2015) (importance of counsel increases in advanced-stage litigation and trial tasks exceed most pro se abilities)
Thornton v. Snyder, 428 F.3d 690 (7th Cir. 2005) (district court may order video trial when serious security concerns exist)
McCaa v. Hamilton, 893 F.3d 1027 (7th Cir. 2018) (courts must separately evaluate a litigant’s personal ability apart from jailhouse-lawyer assistance)
James v. Eli, 889 F.3d 320 (7th Cir. 2018) (circumstances at later litigation stages demand particular judicial consideration)
Bracey v. Grondin, 712 F.3d 1012 (7th Cir. 2013) (state-of-mind claims can increase case complexity for pro se litigants)
Santiago v. Walls, 599 F.3d 749 (7th Cir. 2010) (state-of-mind claims often difficult for pro se plaintiffs)
Dewitt v. Corizon, 760 F.3d 654 (7th Cir. 2014) (distinguishing the pro se litigant’s ability from assistance of a jailhouse lawyer)
Wilborn v. Ealey, 881 F.3d 998 (7th Cir. 2018) (§ 1915(e)(1) does not create indefinite duty to search for volunteer counsel)
Henderson v. Ghosh, 755 F.3d 559 (7th Cir. 2014) (distinguishing denial-of-care claims that require expert proof from those that do not)