James v. Eli

Dist. Ct. erred in granting defendants-prison officials’ motion for summary judgment in section 1983 action filed by plaintiff-prisoner, alleging that defendants were deliberately indifferent to his medical needs concerning his injured toe and fractured jaw, where Dist. Ct. abused its discretion in denying plaintiff’s request for recruitment of counsel at summary judgment stage of case. Plaintiff’s case involved complex medical evidence that required specialized training to understand. Moreover, plaintiff’s incarceration in Arizona at time instant case was prosecuted added to difficulty for plaintiff to present his case, where injury arose in Indiana. Also, Dist. Ct. made only cursory references to factors used to determine whether recruitment of counsel was appropriate when denying plaintiff’s requests for recruitment of counsel without delving into plaintiff’s personal characteristics or specifics of his case. Also, Dist. Ct.’s failure to recruit counsel was prejudicial, where plaintiff was unable to respond to defendant’s summary judgment motion with admissible evidence, and where plaintiff could have, but was unable to obtain his medical records through proper means.