Sinclair v. Culbeaux
- Elizabeth Cowan Wright
- 0:25-cv-02365
- U.S. District Court · District of Minnesota
- 3
In Sinclair v. Culbeaux, Judge Wright denied without prejudice Sinclair’s motion for appointed counsel in her civil-rights case.
Kenya Lenee Sinclair’s request for appointed counsel was denied without prejudice; the order did not decide her underlying claims against Gustavo Culbeaux, the Minnesota State Patrol, or the State of Minnesota.
What happened
In Sinclair v. Culbeaux, Kenya Lenee Sinclair asked the court to appoint a lawyer for her lawsuit against Gustavo Culbeaux, the Minnesota State Patrol, and the State of Minnesota. Her claims arise from an alleged traffic-related incident and include constitutional, disability-discrimination, and state-law claims.
Sinclair said disabilities limited her ability to research the law and write motions, and that her claims were complex. The court found that the facts and legal issues were not overly complex at this early stage. It also found that Sinclair had shown enough ability to explain her claims and position, and noted that she provided no proof of the disabilities she described.
Judge Elizabeth Cowan Wright denied Sinclair’s motion for appointed counsel without prejudice. The order decided only the request for a lawyer, not whether Sinclair’s underlying claims are valid.
The detailed version
- Sinclair v. Culbeaux · No. 0:25-cv-02365
- Elizabeth Cowan Wright
- July 10, 2025
Background
Kenya Lenee Sinclair sued Gustavo Culbeaux in his individual and official capacities, the Minnesota State Patrol, and the State of Minnesota. She brought claims under 42 U.S.C. § 1983 alleging violations of the Fourth Amendment’s protection against excessive force and the Fourteenth Amendment’s due-process guarantee. She also alleged a violation of the Americans with Disabilities Act, specifically 42 U.S.C. § 12132, and several state common-law claims arising from an alleged traffic-related incident.
Sinclair moved for appointment of pro bono counsel based on disability and the alleged complexity of her claims. She submitted a declaration stating that several disabilities limited her ability to conduct legal research and write motions. The defendants’ responses to the complaint were due August 11, 2025.
Legal Standard
The court explained that people in civil cases do not have a constitutional or statutory right to appointed counsel. Under 28 U.S.C. § 1915(e), a court may use its discretion to appoint counsel for an indigent litigant. Relevant considerations include the factual and legal complexity of the case, the litigant’s ability to present the claims, and whether the parties and court would benefit from representation.
The court also noted that the Americans with Disabilities Act does not require courts to provide legal counsel for a person with disabilities.
Court’s Analysis
The court found that neither the facts nor the legal issues were overly complex enough to justify appointing counsel, particularly because the case was still in its early stages. It concluded that Sinclair’s general statements about complexity were not sufficient.
Although Sinclair also relied on disabilities, the court found that she had provided no proof supporting that assertion. The court nevertheless determined that Sinclair had demonstrated the basic ability to explain her claims and argue her position.
Disposition
The court denied without prejudice Sinclair’s Motion to Appoint Pro Bono Counsel due to Disability and Complex Claims. The order did not resolve the merits of Sinclair’s constitutional, disability-discrimination, or state-law claims.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.