Whether and in what context a showing of actual prejudice is required in determining when a court abuses its discretion in failing to grant a continuance or mistrial that results in a civil litigant being forced to proceed pro se, especially where a litigant has a mental disability such as autism.

Specifically, circuit courts disagree regarding whether (1) actual prejudice need be shown at all or is presumed in cases where parties are denied an attorney by a court's ruling and (2) whether, if required, the actual prejudice factor is analyzed (a) in the context of the potential for actual prejudice at the time of the motion hearing or (b) post-hac, after a trial is concluded.

Whether a court abuses its discretion in denying a continuance or mistrial for a mentally disabled civil litigant without showing actual prejudice at the time of the motion, particularly in complex pro se proceedings