Can a court appoint counsel to an indigent plaintiff in a civil case?

It is well-established that there is generally no constitutional right to counsel in civil cases. United States v. Sardone, 94 F.3d 1233, 1236 (9th Cir. 1996). However, under exceptional circumstances, a court may appoint counsel for indigent civil litigants pursuant to 28 U.S.C. 1915(e)(1). When determining whether exceptional circumstances exist, a court considers both the likelihood of success on the merits as well as the ability of the petitioner to articulate [the] claims pro se in light of the complexity of the legal issues involved. Palmer v. Valdez, 560 F.3d 965, 970 (9th Cir. 2009).