Reeves v. Garda World

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
TESHA N. REEVES, 	)
)
Plaintiff, 	)
)
v. 	) 	No. 4:25-cv-01476-RWS
)
GARDA WORLD, 	)
)
Defendant. 	)
MEMORANDUM AND ORDER
This matter is before the Court on (1) Plaintiff’s motion for appointment of counsel (Doc.
3), and (2) Plaintiff’s filing of her “EEOC Inquiry” (Doc. 5). For the following reasons, the Court
denies without prejudice Plaintiff’s motion to appoint counsel and grants her an additional 14 days
to file her EEOC Charge of Discrimination.
In civil cases, a pro se litigant does not have a constitutional or statutory right to appointed
counsel. Ward v. Smith, 721 F.3d 940, 942 (8th Cir. 2013); see also Stevens v. Redwing, 146 F.3d
538, 546 (8th Cir. 1998). Rather, a district court may appoint counsel in a civil case if the court is
“convinced that an indigent plaintiff has stated a non-frivolous claim . . . and where the nature of
the litigation is such that plaintiff as well as the court will benefit from the assistance of counsel.”
Patterson v. Kelley, 902 F.3d 845, 850 (8th Cir. 2018). 	When determining whether to appoint
counsel for an indigent litigant, a court considers relevant factors such as the complexity of the
case, the ability of the pro se litigant to investigate the facts, the existence of conflicting testimony,
and the ability of the pro se litigant to present his or her claim. Phillips v. Jasper Cnty. Jail, 437
F.3d 791, 794 (8th Cir. 2006).
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After reviewing these factors, the Court finds that the appointment of counsel is not
warranted at this time. Plaintiff has demonstrated, at this point, that she can adequately present
her claims to the Court. Additionally, neither the factual nor the legal issues in this case appear to
be complex. 	The Court will entertain future motions for appointment of counsel as the case
progresses.
Additionally, the Court had ordered Plaintiff to submit a copy of her EEOC Charge of
Discrimination. On October 14, 2025, Plaintiff filed a document titled “EEOC (Inquiry) Number:
560-2025-02277.” Doc. 5. This document is not the EEOC Charge of Discrimination. Because
Plaintiff is proceeding pro se, the Court will grant her an additional 14 days to supplement the
complaint by submitting a copy of her EEOC Charge of Discrimination.
Accordingly,
IT IS HEREBY ORDERED Plaintiff’s motion for appointment of counsel is DENIED
without prejudice. (Doc. 3)
IT IS FURTHER ORDERED that Plaintiff shall submit a copy of her EEOC Charge of
Discrimination within 14 days of the date of this Order.
IT IS FURTHER ORDERED that Plaintiff’s failure to comply with this Court’s Order
may result in a dismissal of this action without prejudice.
Dated this 7th day of January, 2026.
RODNEY W. SIPPEL
UNITED STATES DISTRICT JUDGE
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