Background
The appellant, Samar Chatterjee, appealed a decision from the United States District Court for the District of Columbia. The district court had denied a motion to appoint counsel and ruled that it lacked jurisdiction to review a decision of the District of Columbia Superior Court. The district court also found that the appellee judge, Yvonne Williams, was protected by absolute judicial immunity.
The court’s reasoning
The court ordered that the motion to appoint counsel be denied because appellants in civil cases are not entitled to appointment of counsel when they have not demonstrated sufficient likelihood of success on the merits. The court further ordered that the district court’s order be affirmed because the appellant forfeited any challenge to the district court’s conclusion that it lacked jurisdiction by failing to address that point on appeal. The court also found that the district court correctly ruled that the appellee judge had absolute judicial immunity from the appellant’s claims.
In civil cases, appellants are not entitled to appointment of counsel when they have not demonstrated sufficient likelihood of success on the merits.
What it means going forward
The ruling reinforces the standard that civil litigants must show a likelihood of success to secure appointed counsel and confirms that absolute judicial immunity shields judges from liability for their judicial acts. It also establishes that failure to raise jurisdictional objections regarding state court decisions on appeal results in forfeiture of those claims.
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