Garza v. Kleine, 8:24-cv-00054

Robert L. Garza, a prisoner, filed a civil rights case under 42 U.S.C. § 1983 against several officials, challenging his criminal conviction.
The Court previously dismissed Garza's complaint as barred under Heck v. Humphrey because success in this § 1983 action would imply the invalidity of his conviction.
Garza subsequently filed two motions: one requesting the appointment of counsel and another seeking a status update and copies of court documents.
The Court addressed whether to appoint counsel in this closed case and whether to provide copies of documents requested by Garza.
Garza has a history of filing unsuccessful habeas corpus and § 1983 claims relating to his conviction in Nebraska federal court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Dismissal under Heck v. Humphrey	Conviction based on improperly admitted evidence	Relief sought would imply invalid conviction	Claim barred under Heck; case properly dismissed
Request for Appointment of Counsel	Needs counsel due to inability with legal forms	No constitutional/statutory right to counsel	Appointment of counsel denied; discretion exercised
Request for Case Status	Wants update on status of case	N/A	Status motion granted via the issuance of this order
Request for Copies	Seeks certified copy of judge’s order/conviction	No right to free copies	Request for copies denied; no entitlement to free documents

Heck v. Humphrey, 512 U.S. 477 (1994) (barring § 1983 claim that would imply invalidity of conviction without prior invalidation)
Ward v. Smith, 721 F.3d 940 (8th Cir. 2013) (no constitutional or statutory right to counsel in civil cases)
Chambers v. Pennycook, 641 F.3d 898 (8th Cir. 2011) (criteria for appointing counsel in civil cases)
Davis v. Scott, 94 F.3d 444 (8th Cir. 1996) (factors to consider for appointing counsel in § 1983 cases)
Patterson v. Kelley, 902 F.3d 845 (8th Cir. 2018) (indigent prisoners commonly face representation challenges)