Is a pro se party entitled to a competency determination when substantial evidence of incompetence is presented?

With respect to the claim that plaintiff required a guardian ad litem, the general claim that plaintiff was receiving mental health treatment is insufficient to establish that he required the appointment of a guardian ad litem, or was otherwise unable to represent his own interests, at the time he participated in the settlement conference. See Allen v. Calderon, 408 F.3d 1150, 1153 (9th Cir. 2005) (a pro se party "is entitled to a competency determination when substantial evidence of incompetence is presented" (emphasis added)).