The following excerpt is from Berrios v. New York City Housing Authority, 564 F.3d 130 (2nd Cir. 2009):
A party in a civil case has no constitutionally guaranteed right to the assistance of counsel. See, e.g., United States v. Coven, 662 F.2d 162, 176 (2d Cir.1981), cert, denied, 456 U.S. 916, 102 S.Ct. 1771, 72 L.Ed.2d 176 (1982). Thus, although "[t]he court may request an attorney to represent any person unable to afford counsel," 28 U.S.C. 1915(e)(1), it may properly deny a motion to appoint counsel even for a minor or incompetent person"when it is clear that no substantial claim might be brought on behalf of such a party," Wenger, 146 F.3d at 125.
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