George Jones v. Sergeant Ruiz, 478 F. App'x 834

Jones, a Texas prisoner, appeals the denial of his motion for a new trial in a § 1983 excessive force and deliberate indifference case.
Jones argues trial fairness was impaired by deprivation of legal materials by prison officials before trial and by lack of appointed counsel.
The district court applied Rule 59(a) standards, treating a new trial as appropriate only to prevent injustice from prejudicial error.
The district court found Jones had access to substantial legal materials and used them during trial, undermining prejudice claims.
The court held indigent plaintiffs under § 1983 need not always have appointed counsel absent exceptional circumstances.
The appellate panel affirmed the district court, denying relief for deprivation of materials and lack of counsel, and affirmed judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there prejudicial error from deprivation of legal materials?	Jones contends deprivation harmed trial fairness.	Defendants argue no substantial prejudice; Jones had access to materials and used them.	No reversible error; no shown prejudicial impact.
Was appointment of counsel required for an indigent § 1983 plaintiff?	Jones asserts he needed appointed counsel to ensure fair proceedings.	No automatic right to counsel; exceptional circumstances required and not shown here.	Court did not abuse discretion; no exceptional circumstances shown.
Did the district court abuse its discretion in denying a new trial?	Rule 59(a) requires a new trial to prevent injustice based on prejudicial error.	No substantial injustice or harmful error established; discretionary decision proper.	No abuse of discretion; judgment affirmed.

Flores v. United States, 981 F.2d 231 (5th Cir. 1993) (deference to Rule 59(a) discretion; prejudice standard)
Sibley v. Lemaire, 184 F.3d 481 (5th Cir. 1999) (burden of showing harmful error in new trial motions)
Cupit v. Jones, 835 F.2d 82 (5th Cir. 1987) (no automatic appointment of counsel; exceptional circumstances required)
Koch v. Puckett, 907 F.2d 524 (5th Cir. 1990) (conclusory pleadings insufficient to show prejudice)
Parker v. Carpenter, 978 F.2d 190 (5th Cir. 1992) (claims are straightforward; standard of review for mock analysis)
Ulmer v. Chancellor, 691 F.2d 209 (5th Cir. 1982) (factors for appointing counsel in § 1983 indigent actions)
Delta Eng’g Corp. v. Scott, 322 F.2d 11 (5th Cir. 1963) (statutory and procedural grounds for new trials)