Mejia v. Pfister, No. 19-2720 (7th Cir. 2021)Annotate this Case
Illinois inmate Mejia sued correctional officials under 42 U.S.C. 1983, challenging his filthy cell conditions and constant hallway lighting that prevented him from sleeping. His primary claim survived dismissal and summary judgment and proceeded to trial. The jury returned a defense verdict. Mejia had asked the district court, six times, to appoint counsel. Each time the court denied the request, reasoning that Mejia had demonstrated through his many filings that he understood his burden of proof and was capable of assembling evidence and marshaling arguments to support his contention that the Pontiac Correctional Center's conditions of confinement violated the Eighth Amendment.
The Seventh Circuit affirmed. The district court correctly observed that Mejia had an extensive litigation history, including at least one prior case going to trial, albeit with counsel. Mejia had difficulty with the discovery process, but it was within the judge’s discretion to overlook his slips and help him rather than try to recruit counsel. The court observed, during the pretrial conference, Mejia’s ability to comprehend and address the facts and issues pertinent to his Eighth Amendment claim. There was no abuse of discretion; the fact that some trial witnesses testified by videoconference does not change the analysis.