(PC) Quarles v. California State Prison Corcoran, 1:19-cv-00109

Plaintiff Nikko Javor Quarles is a state prisoner proceeding pro se and in forma pauperis in a 42 U.S.C. § 1983 civil-rights action.
On January 3, 2022 Quarles filed a second motion for appointment of counsel, stating he will need trial counsel expertise.
The Court had previously denied an earlier request for appointed counsel and Quarles offered no new reasons in the current motion.
The Court reviewed the governing discretionary standard under 28 U.S.C. § 1915(e)(1) and Ninth Circuit guidance requiring "exceptional circumstances" to appoint counsel in civil cases.
The Court found Quarles has capably litigated to date (filed motions; complaint survived initial screening) and did not demonstrate exceptional circumstances.
The motion for appointment of counsel was denied without prejudice to renewal if circumstances change as the case proceeds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court should appoint counsel under 28 U.S.C. § 1915(e)(1)	Quarles: needs counsel’s expertise for trial	Velasquez et al.: opposition not detailed; no obligation shown	Denied — no exceptional circumstances shown

Lewis v. Casey, 518 U.S. 343 (no constitutional right to appointed counsel in civil cases)
Bounds v. Smith, 430 U.S. 817 (discussing limits on the right to counsel in prison-related contexts)
United States v. McQuade, 519 F.2d 1180 (9th Cir.) (identifies "exceptional circumstances" standard for civil appointment of counsel)
Rand v. Rowland, 113 F.3d 1520 (9th Cir.) (lists factors courts may consider when deciding appointment of counsel)