Cameron v. Renewal by Anderson LLC
- Nancy Brasel
- 0:25-cv-02920
- U.S. District Court · District of Minnesota
- 2
In Cameron v. Renewal by Anderson LLC, Magistrate Judge Foster denied plaintiff Mikayle Cameron's request to have a lawyer appointed for him at no cost, but referred him to a volunteer lawyer program that could provide free consultations.
Self-represented (pro se) civil litigants in the District of Minnesota who seek court-appointed counsel in civil cases, and specifically Mikayle Cameron in this case.
What happened
In Cameron v. Renewal by Anderson LLC (Case No. 25-cv-2920), Mikayle Cameron, who is representing himself without a lawyer, asked the court to appoint an attorney for him because he lacks legal training and resources to handle discovery and trial. He filed this motion in federal court in the District of Minnesota.
The court explained that there is no automatic right to a free, court-appointed lawyer in civil (non-criminal) cases. Instead, judges have discretion to appoint counsel based on five factors: how complex the facts and law are, whether the person can investigate the facts and present their arguments, and whether there is conflicting testimony. The court found that this case does not involve especially complex facts or law, and that Mr. Cameron has already shown he can research and present his arguments, as demonstrated by documents he has already filed in the case.
Magistrate Judge Foster denied Mr. Cameron's motion for appointment of counsel, finding that his lack of resources alone — without other distinguishing factors — is not enough to warrant appointing a lawyer, since many self-represented litigants face similar circumstances. However, the court referred Mr. Cameron to the Pro Se Project of the Minnesota Chapter of the Federal Bar Association, a voluntary program where a volunteer attorney may consult with him about his case at no charge. The court indicated it would send Mr. Cameron a separate letter with more details about the program.
The detailed version
In Mikayle Cameron v. Renewal by Anderson LLC, Case No. 25-cv-2920 (NEB/DJF), United States Magistrate Judge Dulce J. Foster issued an order on November 7, 2025, ruling on plaintiff Mikayle Cameron's Motion for Appointment of Counsel (ECF No. 30).
Background and Motion
Mr. Cameron is proceeding pro se (representing himself without an attorney) in a civil case against Renewal by Anderson LLC in the District of Minnesota. He moved for the court to appoint counsel on the grounds that he lacks the legal training and financial resources necessary to handle discovery (the pre-trial process of exchanging evidence) and trial proceedings.
Legal Standard
The court cited Eighth Circuit precedent establishing that there is no constitutional or statutory right to appointed counsel in civil cases. Ward v. Smith, 721 F.3d 940, 942 (8th Cir. 2013). Appointment is a matter of judicial discretion, guided by five factors from Crozier v. Westside Cmty. Sch. Dist., 973 F.3d 882, 889 (8th Cir. 2020): (1) the factual complexity of the issues; (2) the pro se litigant's ability to investigate the facts; (3) the existence of conflicting testimony; (4) the litigant's ability to present his claims; and (5) the complexity of the legal arguments.
Analysis and Ruling
The court denied the motion. It found that neither the factual nor the legal issues in the case are particularly complex. It further found that Mr. Cameron has demonstrated an ability to investigate facts and present arguments, citing his complaint (ECF No. 1) and another filing (ECF No. 20). The court also found that financial hardship alone does not warrant appointment of counsel, as it does not distinguish Mr. Cameron's situation from that of the many other pro se litigants in similar circumstances.
Referral to Pro Se Project
Despite denying the motion, the court referred Mr. Cameron to the Pro Se Project of the Minnesota Chapter of the Federal Bar Association. This is a voluntary program in which a volunteer attorney may consult with Mr. Cameron about his case without charging a fee. The court noted it would send him a separate letter with additional details about the program.
Reviewer note from the AI+
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