Compulsory appointment in prisoner civil rights case?

The district court in Naranjo v. Thompson found that Naranjo, a prisoner in the Reeves County Detention Center, had shown “exceptional circumstances” that warranted the appointment of counsel to pursue his civil rights claims about the conditions of his incarceration.  (Foremost among them was the prisoner’s inability to review a number of documents that were filed under seal due to security concerns.)  The court went on to conclude, however, that no local attorneys were available and that it lacked the power to make a compulsory appointment.  The Fifth Circuit reversed, finding that a district court has the inherent power to make such an appointment, but reminding that “this is a power of last resort” and that “[i]nherent powers ‘must be used with great restraint and caution.'” Accordingly, the Court reversed a summary judgment for the defendants and remanded for proceedings consistent with its ruling about inherent power.