What is the test for denial of appointment of counsel for abuse of discretion?

MultiRegion, United States of America

The following excerpt is from Jackson v. U.S. Postal Service, 888 F.2d 1394 (9th Cir. 1989):

We review the district court's denial of appointment of counsel for abuse of discretion. Bradshaw v. Zoological Soc'y, 662 F.2d 1301, 1318 (9th Cir.1981). Although appellant appears to have made some effort to obtain counsel and has shown he lacks the financial resources to do so, he has not made a sufficient showing as to the merits of his claim. See id. Conclusory allegations of fraud and constitutional violations do not suffice to state a meritorious Title VII claim. The court did not abuse its discretion.

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