Gibson v. Tolbert

James Tolbert is an indigent inmate who filed a pro se medical malpractice claim against Dr. Louis Gibson, a prison doctor who provided medical services to Tolbert. Tolbert asked the trial court to appoint counsel. The motion was never granted, and the trial court later dismissed the case. Tolbert appealed only the denial of appointed counsel. The court of appeals reversed the dismissal, holding that Tolberts civil suit was an "exceptional case" requiring appointed counsel. Without hearing oral argument, we reverse the court of appeals judgment and hold that an indigent inmate does not have a right to appointed counsel in a civil case merely because the inmates suit is against an employee of the prison in which the inmate is incarcerated.