Monson v. Renville County Jail and Ned Wohlman
Chad Lee Monson v. Renville County Jail and Ned Wohlman, in his individual and official capacity
- Katherine Menendez
- 0:25-cv-01665
- U.S. District Court · District of Minnesota
- 2
In Monson v. Renville County Jail and Ned Wohlman, Magistrate Judge Foster denied plaintiff Chad Lee Monson's request for a court-appointed lawyer in his civil case but gave him until December 15, 2025 to respond to the defendants' motion to dismiss.
Pro se (self-represented) civil litigants who cannot afford a lawyer and are seeking court-appointed counsel in federal civil cases, particularly in the District of Minnesota. Also directly affects the parties in this case regarding the new briefing schedule on the pending motion to dismiss.
What happened
In Monson v. Renville County Jail and Ned Wohlman (Case No. 25-cv-1665), plaintiff Chad Lee Monson, who is representing himself, filed two motions: one asking the court to appoint a lawyer for him, and one asking for more time to respond to the defendants' motion to dismiss his case. The defendants are Renville County Jail and Ned Wohlman, sued in both his personal and official capacity.
On the request for a lawyer, the court explained that in civil cases there is no automatic right to a court-appointed attorney, even for people who cannot afford one. The court has the discretion to appoint counsel by weighing factors such as how complicated the facts and legal issues are, whether the person can investigate facts and present arguments on their own, and whether there is conflicting testimony. The court found that Mr. Monson's case does not involve especially complex facts or law, and that he has shown some ability to conduct legal research and present his arguments, so his lack of legal training alone was not enough to justify appointing a lawyer.
Magistrate Judge Foster denied the motion for appointment of counsel but granted the request for more time. Because Mr. Monson had been waiting for the court's decision on the lawyer question before responding to the motion to dismiss, the court found good cause to extend his deadline. Mr. Monson must file his response to the motion to dismiss by December 15, 2025, and the defendants may file a reply by January 5, 2026.
The detailed version
Case: Chad Lee Monson v. Renville County Jail and Ned Wohlman, in his individual and official capacity, No. 25-cv-1665 (KMM/DJF). Decided November 24, 2025 by United States Magistrate Judge Dulce J. Foster, District of Minnesota.
Background
Plaintiff Chad Lee Monson is a pro se litigant (a person representing himself without a lawyer) who was previously granted leave to proceed in forma pauperis (without paying court filing fees, IFP). He filed two motions: (1) a Motion for Appointment of Counsel (ECF No. 17), and (2) a Motion for Extension of Time to respond to Defendants' Motion to Dismiss (ECF No. 19).
Motion for Appointment of Counsel — Denied
Mr. Monson argued that because he was granted IFP status and because 28 U.S.C. § 1915(e)(1) authorizes the court to request an attorney for someone who cannot afford one, counsel should be appointed. The court acknowledged this statutory authority but noted — including by citing Mr. Monson's own submitted exhibit — that the statute does not guarantee appointed counsel in civil cases. Citing Ward v. Smith, 721 F.3d 940, 942 (8th Cir. 2013), the court reaffirmed that there is no constitutional or statutory right to appointed counsel in civil matters; appointment is purely discretionary. Applying the five-factor test from Crozier v. Westside Community School District, 973 F.3d 882, 889 (8th Cir. 2020) — (1) factual complexity, (2) ability to investigate facts, (3) existence of conflicting testimony, (4) ability to present claims, and (5) complexity of legal arguments — the court found none of the factors weighed in favor of appointment. The court noted that Mr. Monson's case does not involve particularly complex facts or legal arguments, that he demonstrated some capacity for legal research, and that his lack of access to legal assistance does not distinguish him from the many other pro se litigants. The motion was DENIED.
Motion for Extension of Time — Granted
Mr. Monson's extension request was premised on his pending motion for counsel. Now that the counsel question was resolved, the court found good cause to grant the extension because Mr. Monson had been reasonably waiting on the court's decision before preparing his response. The court GRANTED the Motion for Extension. New deadlines set: Mr. Monson's response to Defendants' Motion to Dismiss (ECF No. 10) is due December 15, 2025; Defendants' reply is due January 5, 2026.
Disposition
Motion for Appointment of Counsel (ECF No. 17) — DENIED. Motion for Extension of Time (ECF No. 19) — GRANTED.
Reviewer note from the AI+
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.