McCaa v. Hamilton
893 F.3d 1027
| 7th Cir. | 2018Background
- McCaa, a pro se prisoner with documented mental illness and limited education, sued Green Bay Correctional Institution staff under 42 U.S.C. § 1983 for deliberate indifference to his risk of self-harm across four incidents (2013–2015).
- The district court screened the complaint under 28 U.S.C. § 1915A and allowed five deliberate-indifference claims to proceed.
- McCaa filed four motions to recruit counsel under 28 U.S.C. § 1915(e); the district court denied all four (initial denials were without detailed analysis of certain competency factors).
- By the time of the third motion the case entered discovery; McCaa reported transfer to another facility and reduced assistance from other inmates, and he asserted difficulty conducting discovery and contacting witnesses.
- The district court granted summary judgment for defendants after concluding McCaa failed to properly cite evidence; it treated defendants’ proposed facts as undisputed, and denied McCaa’s fourth counsel motion as moot given the summary-judgment ruling.
- The Seventh Circuit recruited counsel for the appeal, found the district court abused its discretion by not addressing specific factors bearing on McCaa’s competence when denying the third counsel motion, held that error was prejudicial, vacated the judgment, and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion denying recruitment of counsel under 28 U.S.C. § 1915(e) | McCaa argued he reasonably sought counsel and, given mental illness, limited education, transfer, reliance on other inmates, and case complexity in discovery, he was not competent to litigate alone | Defendants contended McCaa’s filings showed he could coherently litigate and the appearance of an additional defense attorney did not show complexity | Court: Abuse of discretion for denying the third motion because the court failed to address transfer, reliance on jailhouse assistance, and the increased discovery complexity; remanded |
| Whether any abuse was prejudicial | McCaa argued lack of counsel caused failure to obtain and properly present discovery and evidence at summary judgment | Defendants pointed to procedural deficiencies in McCaa’s filings and argued merits favored summary judgment | Court: Prejudice shown — reasonable likelihood a lawyer would have preserved/disputed facts and created genuine issues to avoid summary judgment |
| Whether deliberate-indifference claims are categorically too complex for pro se litigants | McCaa argued the state-of-mind issues and discovery needs made the claims complex | Defendants argued state-of-mind issues are not categorically too complex and McCaa had litigated competently so far | Court: No categorical rule; complexity is case-specific. Here court needed to consider whether complexity exceeded McCaa’s capacity and failed to do so adequately |
| Whether district court properly enforced summary-judgment procedural rules against a pro se, mentally ill litigant | McCaa argued strict enforcement unfairly extinguished his claims because he failed to cite evidence due to lack of counsel and disability | Defendants argued local rules were properly applied and McCaa failed to follow them | Court: Did not rule that strict enforcement was improper generally, but found that the denial of counsel contributed to a prejudicial outcome when coupled with strict enforcement |
Key Cases Cited
- Pruitt v. Mote, 503 F.3d 647 (7th Cir. 2007) (framework for recruiting counsel under § 1915(e): attempt to obtain counsel and plaintiff competence given case difficulty)
- James v. Eli, 889 F.3d 320 (7th Cir. 2018) (district court must address particular circumstances that bear on recruitment decision)
- Dewitt v. Corizon, Inc., 760 F.3d 654 (7th Cir. 2014) (need to examine plaintiff’s personal ability vs. assistance from jailhouse lawyers)
- Santiago v. Walls, 599 F.3d 749 (7th Cir. 2010) (transfers can impede prisoners’ ability to locate witnesses and litigate)
- Olson v. Morgan, 750 F.3d 708 (7th Cir. 2014) (state-of-mind issues are not categorically too difficult for pro se litigants)
- Henderson v. Ghosh, 755 F.3d 559 (7th Cir. 2014) (deliberate-indifference claims often turn on defendants’ state of mind and can be factually demanding)
- Martin v. Franklin Capital Corp., 546 U.S. 132 (U.S. 2005) (district-court discretion in ancillary matters should be guided by sound legal principles)