What is the current state of the law on notice of deficiency in a complaint?

Additionally, in the years since Hudson was decided, we have developed other procedural protections for pro se litigants. See, e.g., Eldridge v. Block, 832 F.2d 1132, 1136 (9th Cir.1987) (reaffirming that trial courts have a duty to provide pro se litigant notice of complaint deficiencies with opportunity to correct unless amendment would be futile); Balistreri v. Pacifica Police Dept., 901 F.2d 696, 699 (9th Cir.1990) (noting that courts have a general duty "to ensure that pro se litigants do not lose their right to a hearing on the merits of their claim due to ignorance of technical procedural requirements").