Order | Filed: September 21, 2026
| Entered: September 21, 2026
Box v. Stratas Foods LLC
Civil Rights: Jobs | Illinois Central
Order on Motion to Request Counsel Order on Motion for Leave to File
TEXT ORDER: Plaintiff's Motion to Request Counsel 18 is DENIED. Parties in civil cases do not have a right, either constitutional or statutory, to counsel. See Zarnes v. Rhodes, 64 F.3d 285, 288 (7th Cir. 1995). Under 28 U.S.C. § 1915(e)(1), the Court may request an attorney for a party unable to afford one, applying the two-step inquiry from Pruitt v. Mote, 503 F.3d 647, 653-55 (7th Cir. 2007) (en banc). At step one, Plaintiff attests he contacted four law firms "during June 2026"; one quoted a retainer he could not afford, and three declined representation. He does not explain why those firms declined or provide details of the discussions, and he supplies no corroboration (such as rejection letters). See Thomas v. Wardell, 951 F.3d 854, 858-60 (7th Cir. 2020) (affirming finding of unreasonable efforts where plaintiff's letters lacked claim information); see also Stokes v. Wexford Health Services, 2025 WL 1432975, at *1 (S.D. Ill. May 19, 2025) (requiring rejection letters from at least three attorneys). On this record, the Court finds Plaintiff has not made a reasonable attempt to obtain counsel. Plaintiff has also filed a Motion for Leave to File Reply 20 , attaching his proposed reply. The Motion for Leave 20 is GRANTED, and the Court has considered the proposed reply. In it, Plaintiff provides additional detail regarding his efforts to obtain counsel, including the names of the attorneys or firms he contacted and his explanation that the contacts occurred by telephone and therefore did not generate written rejection letters. Even considering this additional information, however, recruitment of counsel is not warranted. Regardless of whether Plaintiff's additional showing is sufficient to satisfy the first step of the Pruitt inquiry, Plaintiff fails at step two. At step two, the question is whether, given the factual and legal difficulty of the case, the plaintiff appears competent to litigate it himself, including the ordinary tasks of evidence gathering, motion practice, and trial. Pruitt, 503 F.3d at 655; Navejar v. Iyiola, 718 F.3d 692, 696 (7th Cir. 2013). Here, Plaintiff has personal knowledge of the facts at issue, and the case does not present overly complex questions of law or fact. He has communicated effectively with the Court and has filed cogent submissions that include exhibits and memoranda in compliance with the Federal and Local Rules. Considering the record, the nature of the claims, and the stage of proceedings, the difficulty of this case does not exceed Plaintiff's capacity to present it. Accordingly, Plaintiff's Motion for Leave to File Reply 20 is GRANTED, and Plaintiff's Motion to Request Counsel 18 is DENIED. Entered by Magistrate Judge Ronald L. Hanna on 9/21/2026. (ECJ)