Camargo v. SSA Commissioner
- Thomas Hixson
- 3:25-cv-08552
- U.S. District Court · Northern District of California
- 2
In Pablo Camargo v. SSA Commissioner, Judge Hixson denied Pablo Camargo’s request for appointed counsel without prejudice.
Pablo Camargo’s request for appointed counsel was denied without prejudice; the underlying case was not decided by this order.
What happened
Pablo Camargo v. SSA Commissioner concerns Camargo’s request for the court to appoint a lawyer in his civil case. He used a form stating that the case involved complex legal and factual issues.
The court explained that civil litigants generally do not have a right to appointed counsel. Appointment may be possible in exceptional circumstances, but Camargo was not proceeding under the status required for appointed counsel, and the case did not appear unusually complex.
Judge Hixson denied the request without prejudice. The court said Camargo had sufficiently explained his claims without a lawyer, his likelihood of success was unclear at this early stage, and he provided no evidence beyond form language that he had tried to find a lawyer. The court left open the possibility of appointing counsel on its own initiative if circumstances later required it.
The detailed version
- Camargo v. SSA Commissioner · No. 3:25-cv-08552
- Thomas Hixson
- Oct. 8, 2025
Background
On October 7, 2025, Pablo Camargo asked the court to appoint a lawyer for him. His request used a template form with standard language asserting that the case involved complex legal and factual issues.
Legal standard
The court stated that people generally have no right to appointed counsel in civil actions. Under 28 U.S.C. § 1915(e)(1), a court may appoint counsel for an indigent civil litigant in exceptional circumstances. The court explained that a person seeking appointed counsel must be proceeding in forma pauperis, a status for litigants who cannot afford the costs of the case, and must lack the financial resources to hire counsel. In deciding whether exceptional circumstances exist, courts consider both the likelihood of success on the merits and the litigant’s ability to explain the claims without a lawyer given the complexity of the legal issues. Neither consideration alone controls.
Court’s analysis
The court found that Camargo was not entitled to appointed counsel because he was not proceeding in forma pauperis. The court added that, even if he had that status, the likelihood of success was unclear at this early stage, while he had so far explained his claims sufficiently without a lawyer. The issues did not appear unusually complex, and the court found no indication that discovery would be so complex that counsel was necessary. The court also noted that Camargo’s form asserted that he had made a good-faith effort to find counsel but provided no evidence or explanation of any effort beyond those statements.
Disposition
Judge Thomas S. Hixson denied Camargo’s request without prejudice. The order preserved the possibility that the court could appoint counsel on its own initiative if circumstances later required it. The court also referred Camargo to the Legal Help Center and to the district court’s handbook for litigants without a lawyer; the Legal Help Center could provide basic legal help but not representation.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.