ORDER

ALLISON CLAIRE, Magistrate Judge.

The court is in receipt of plaintiff's motion to appoint counsel. ECF No. 26. Plaintiff is incarcerated, and is bringing his civil rights case under 42 U.S.C. § 1983 as a self-represented litigant proceeding in forma pauperis. ECF No. 1, 2, 5 and 10.

I. Motion

Plaintiff makes a second request that the court appoint counsel. ECF No. 26. Plaintiff acknowledges this court has already denied a previous motion to appoint counsel. ECF No. 11. Plaintiff assets he needs counsel because he is disadvantaged due to imprisonment with respect tot participating in discovery, contacting witnesses, and gathering outside evidence. ECF No. 26 at 1.

II. Analysis

As previously explained to plaintiff, district courts lack authority to require counsel to represent indigent prisoners in section 1983 cases. Mallard v. United States Dist. Court, 490 U.S. 296, 298 (1989). In exceptional circumstances, the court may request an attorney to voluntarily to represent such a plaintiff. See 28 U.S.C. § 1915(e)(1); Terrell v. Brewer, 935 F.2d 1015, 1017 (9th Cir. 1991); Wood v. Housewright, 900 F.2d 1332, 1335-36 (9th Cir. 1990). When determining whether "exceptional circumstances" exist, the court must consider the likelihood of success on the merits as well as the ability of the plaintiff to articulate his claims pro se in light of the complexity of the legal issues involved. Palmer v. Valdez, 560 F.3d 965, 970 (9th Cir. 2009).

Having considered the relevant factors, the court finds there are no exceptional circumstances in this case, and that appointment of counsel remains unwarranted. Plaintiff's case is not overly complex. See ECF No. 1. Plaintiff's alleged difficulty in participating in litigation due to his imprisonment does not constitute exceptional circumstances. "Circumstances common to most prisoners, such as lack of legal education and limited law library access, do not establish exceptional circumstances that would warrant a request for voluntary assistance of counsel." Kent v. U.C. Davis Med. Ctr., No. 215CV1924WBSACP, 2016 WL 4208572, at *1 (E.D. Cal. Aug. 10, 2016). Appointment of counsel therefore is not appropriate.

III. Conclusion

Plaintiff's motion to appoint counsel (ECF No. 26) is DENIED.

IT IS SO ORDERED.