The following excerpt is from McEndree v. Lozano, Case No. 18-cv-2772-BAS-NLS (S.D. Cal. 2018):
The Constitution provides no right to appointment of counsel in a civil case unless an indigent litigant may lose her physical liberty if she loses the litigation. Lassiter v. Dep't of Soc. Servs., 452 U.S. 18, 25 (1981). Even where the plaintiff is proceeding pro se or in forma pauperis, district courts do not have the authority "to make coercive appointments of counsel." Mallard v. United States Dist. Court, 490 U.S. 296, 310 (1989). However, "the court may request an attorney to represent any
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