This case raise the question whether the procedural treatment currently to Pro-Se Litigants by federal courts comports with due process or whether more leiniency is required to preserve the litigants meaningful opportunity to be heard?

Particularly given the leiniency typically afforded Pro-Se litigants that unfortunate series of events should not deprive petitioner of his day in court. As the court recognized on several occasions ovigating the appellate process without a lawyer 's assistance is a perilous endeavor for a lay person. (Halbert V. Michigan, 545 U.S. 605, 621 (2005).

Whether the procedural treatment currently afforded to pro-se litigants by federal courts comports with due process or whether more leniency is required to preserve the litigant's meaningful opportunity to be heard