Rangel v. Williams
- Jacquelyn Corley
- 3:21-cv-00278
- U.S. District Court · Northern District of California
- 2
In Rangel v. Williams, Judge Corley denied Rangel’s requests for counsel and more law-library time, citing no complexity and lack of jurisdiction over nonparties.
Jonathan Rangel’s requests for a lawyer and additional law-library access were denied; the underlying civil-rights claims were not decided in this order.
What happened
In Rangel v. Williams, Jonathan Rangel, a California prisoner, brought a civil-rights case under a federal law allowing lawsuits against state officials for constitutional violations. He asked the court to find him a lawyer.
Rangel also asked the court to order prison officials to increase his law-library access from two hours to six hours per week. He said he wanted more time to learn the federal and local court rules, but he did not have a filing deadline at that time.
Judge Jacquelyn Corley denied both motions. She said Rangel had presented his claims effectively, the issues were not complex at that stage, and the court lacked authority to order nonparties such as the prison officials involved in the library request.
The detailed version
- Rangel v. Williams · No. 3:21-cv-00278
- Jacquelyn Corley
- Mar. 23, 2021
Background
Jonathan Rangel, identified as a California prisoner, filed this civil-rights case under 42 U.S.C. § 1983. He filed a motion seeking appointment of counsel and a separate motion asking the court to order prison officials to increase his weekly law-library access from two hours to six hours.
Motion for Counsel
The court explained that there is no constitutional right to a lawyer in a civil case. It also explained that 28 U.S.C. § 1915(e)(1) gives a district court authority to request that a lawyer represent a person proceeding without paying court fees, rather than authority to appoint a lawyer over the lawyer’s objection.
The court found that Rangel had presented his claims effectively and that the issues were not complex, at least at that stage of the case. It therefore denied the motion for appointment of counsel. The court stated that, if circumstances changed and Rangel needed a lawyer, it would refer the case to the Federal Pro Bono Project to look for a lawyer willing to represent him without charge.
Motion for Additional Law-Library Access
Rangel asked the court to increase his weekly law-library time from two hours to six hours so he could become familiar with the Federal Rules of Civil Procedure and the Northern District of California’s Local Rules. The court noted that Rangel did not then have a filing deadline. It also noted that the defendants were health-care employees at Salinas Valley State Prison.
The court stated that it did not have jurisdiction—the legal authority to issue the requested order—over nonparties, including the prison officials involved in the law-library request. The court denied the motion for additional law-library access. The opinion states that, if Rangel later had a deadline, he could renew his request to prison officials for additional library hours or ask the court for more time.
Disposition
Judge Jacquelyn Corley denied both motions: the motion for appointment of counsel and the motion for additional law-library access.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.