This Note examines the Supreme Court's recent attempt in Mallard v. United States District Court to answer the question whether a federal court, pursuant to 28 U.S.C. § 1915(d), may compel an unwilling attorney to represent an indigent civil litigant. Following an examination of the Court's opinion in Mallard, the discussion focuses on the questions the Court left unanswered. While the Court was faced with the opportunity to resolve the question of mandatory appointments of counsel for indigent civil litigants, it instead chose to step out of harm's way, leaving unanswered questions whose resolutions are needed today.

I. Introduction

II. Mallard: Defining the Word "Request"

III. Mallard: Questions for Another Day ... A. Officer of the Court: The Weak Historical Foundation of an Over-Used Doctrine ... B. Officer of the Court Doctrine as a Justification for Denial of Constitutional Rights ... C. Officer of the Court Doctrine and a Lawyer's Responsibilities to the Legal Profession: The Horns of an Ethical Dilemma

IV. Conclusion