Pinson v. Federal Bureau of Prisons

Background

Jeremy Pinson, proceeding without a lawyer, filed a motion that the court understood to renew his request for appointed counsel, seek restoration of access to the courts, and request more time to file a reply to the Federal Bureau of Prisons’ opposition. The court had previously granted extensions and had previously denied a request for free appointed counsel.

Pinson alleged that, after being moved from a general-population housing unit to a segregated housing unit on April 4, 2025, he spent 23 to 24 hours per day in his cell, lacked access to his legal files, and could use the law library for only 20 minutes per day. He also alleged that the library lacked a printer and photocopier.

Appointment of Counsel

The court explained that people seeking habeas relief generally have no constitutional right to a lawyer. Pinson argued that his request should be considered under 18 U.S.C. § 3006A(a)(2)(B), which permits appointed representation for a financially eligible person seeking relief under 28 U.S.C. § 2241 when the interests of justice require it. The court agreed that this statute governs such requests but stated that courts in the district analyze appointment requests under the same standards used for appointed counsel in civil cases under 28 U.S.C. § 1915(e)(1). Relying on the reasons explained in its earlier order, the court denied the request for counsel without prejudice to renewal later.

Access to the Courts

The court stated that prisoners have a constitutional right to a reasonably adequate opportunity to present constitutional claims. But that right does not create an independent entitlement to a law library or legal assistance. A prisoner must show that shortcomings in legal resources or assistance actually hindered a legal claim.

The court found Pinson’s allegations insufficient. He did not connect the lack of a printer or photocopier to an actual injury. He also alleged only that 20 minutes per day was insufficient, without identifying an injury caused by that limit; for example, he did not say that he had missed a deadline. The court also noted that Pinson had regular law-library access and that prison administrators generally have substantial discretion to manage their facilities. It denied the request to restore access to the courts without prejudice.

Extension and Disposition

The court granted Pinson one final extension to file his reply. The reply was due on or before August 1, 2025, and the court stated that no further extensions would be granted. Judge Mary Kay Vyskocil ordered that the motions for appointed counsel and restoration of court access were denied without prejudice, the extension request was granted, and the docketed motion was terminated. The court also certified that an appeal would not be taken in good faith and denied permission to appeal without paying filing fees.