Opinion
No. 15-1811
04-28-2016
Chase Carmen Hunter Plaintiff - Appellant v. Jay Bradford, Individually and in his Official Capacity as Commissioner of Insurance for Arkansas; Arkansas Insurance Department; National Association of Insurance Commissioners; National Insurance Producer Registry; Eleanor Kitzman, Individually and in Her Official Capacity; Julia Rathgeber, Individually and in Her Official Capacity as the Commissioner of the Texas Department of Insurance; Texas Department of Insurance; Dave Jones, Individually and in His Official Capacity as the Commissioner of Insurance of the California Department of Insurance; California Department of Insurance Defendants - Appellees
Appeal from United States District Court for the Eastern District of Arkansas - Little Rock [Unpublished] Before GRUENDER, ARNOLD, and SHEPHERD, Circuit Judges. PER CURIAM.
In this interlocutory appeal, Virginia resident Chase Hunter challenges the district court's denial of her motions for appointment of counsel, and for a temporary restraining order (TRO) to prevent defendants from revoking her Arkansas insurance agent license.
The Honorable Kristine G. Baker, United States District Judge for the Eastern District of Arkansas. --------
We hold that the district court did not abuse its discretion in denying Ms. Hunter's motion for appointment of counsel, as the legal issues were not technical or complex, and there was no indication that Ms. Hunter was unable to investigate the facts or present her claims on her own. See Stevens v. Redwing, 146 F.3d 538, 546 (8th Cir. 1998) (standard of review and applicable factors); Slaughter v. City of Maplewood, 731 F.2d 587, 588-89 (8th Cir. 1984) (denial of appointment of counsel is immediately appealable). We conclude that we lack jurisdiction over the denial of Ms. Hunter's motion for a TRO. See Carson v. American Brands, Inc., 450 U.S. 79, 84 (1981) (interlocutory appeal of TRO is available only if litigant shows that order had practical effect of refusing injunction, and that litigant would suffer "serious, perhaps irreparable consequence" that could only be effectually challenged by immediate appeal; if permanent injunctive relief may be obtained after trial, interlocutory order is not appealable).
Accordingly, we affirm the denial of appointed counsel. See 8th Cir. R. 47B.