The following excerpt is from Gipbsin v. Roth, No. 2:18-cv-03164-TLN-CKD (E.D. Cal. 2020):
1. In certain "exceptional circumstances," a court may appoint an attorney to represent a pro se plaintiff. See 28 U.S.C. 1915(e)(1); Terrell v. Brewer, 935 F.2d 1015, 1017 (9th Cir. 1991). Determining whether "exceptional circumstances" exist requires consideration of the plaintiff's "likelihood of success on the merits as well as the ability of the [plaintiff] to articulate his claims pro se in light of the complexity of the legal issues involved." Palmer, 560 F.3d at 970.
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