The following excerpt is from U.S. v. 30.64 Acres of Land, More or Less, Situated in Klickitat County, State of Wash., 795 F.2d 796 (9th Cir. 1986):
Courts may also impose additional burdens [in addition to passing on the sufficiency of the complaint] before appointing counsel for indigents in civil suits. See Johnson v. Avery, 393 U.S. 483, 487-88 [89 S.Ct. 747, 749-50, 21 L.Ed.2d 718] (1969).
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