Unreported / Non-Citable
Background
Melvin Wayne Williams, a Texas prisoner, filed a civil-rights action in July 2025 concerning medical care he received from July through September 2022 while detained in the Burleson County Jail. He alleged that jail and medical personnel violated his constitutional rights.
The U.S. District Court for the Western District of Texas dismissed the complaint as frivolous under 28 U.S.C. § 1915(e), concluding that the applicable statute of limitations barred the action. Williams appealed and requested appointment of counsel.
The Court’s Holding
In an unpublished per curiam opinion, the Fifth Circuit agreed with the district court that Williams’s complaint was time-barred. The court therefore affirmed the dismissal.
The court also concluded that the case did not present exceptional circumstances warranting appointed counsel and denied Williams’s motion for appointment of counsel.
Key Takeaways
- A prisoner’s civil-rights complaint concerning medical care received from July through September 2022 was untimely when filed in July 2025.
- The Fifth Circuit affirmed the complaint’s dismissal as frivolous under 28 U.S.C. § 1915(e) because the statute of limitations barred the claims.
- Appointment of counsel was unwarranted because the case did not involve exceptional circumstances.
Why It Matters
The decision reinforces that limitations defenses may support dismissal during screening under § 1915(e) when untimeliness is apparent. Prisoners pursuing constitutional claims concerning jail medical care must file within the applicable limitations period.
It also confirms that indigent civil litigants are not entitled to appointed counsel absent exceptional circumstances.