Does a court have to pass on the sufficiency of the complaint to appoint counsel for an indigent in a civil action?

MultiRegion, United States of America

The following excerpt is from U.S. v. 30.64 Acres of Land, More or Less, Situated in Klickitat County, State of Wash., 795 F.2d 796 (9th Cir. 1986):

Courts may also impose additional burdens [in addition to passing on the sufficiency of the complaint] before appointing counsel for indigents in civil suits. See Johnson v. Avery, 393 U.S. 483, 487-88 [89 S.Ct. 747, 749-50, 21 L.Ed.2d 718] (1969).

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