Does a plaintiff have a constitutional right to counsel in a civil action brought by an indigent litigant?

There is no constitutional right to counsel in a civil case unless an indigent litigant may lose his physical liberty if he loses the litigation. See Lassiter v. Dep't of Soc. Servs., 452 U.S. 18, 25 (1981); Rand v. Rowland, 113 F.3d 1520, 1525 (9th Cir. 1997) (no constitutional right to counsel in 1983 action), withdrawn in part on other grounds on reh'g en banc, 154 F.3d 952 (9th Cir. 1998) (en banc). Title 28 U.S.C. 1915 confers on a district court only the power to "request" that counsel represent a litigant who is proceeding in forma pauperis. See 28 U.S.C. 1915(e)(1).