The following excerpt is from Sears v. Sacramento County and Management, 21 F.3d 1115 (9th Cir. 1994):
Appointment of counsel under section 28 U.S.C. Sec. 1915(d) is left to the sound discretion of the trial court and is appropriate only in "exceptional circumstances" where the legal issues are complex. Wood v. Housewright, 900 F.2d 1332, 1335 (9th Cir.1990). Because this case does not involve exceptional circumstances, the district court did not abuse its discretion by declining to appoint counsel. See id.
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