What is the legal test for drafting a pleading in a pro se proceeding?

MultiRegion, United States of America

The following excerpt is from Smith v. Rodriguez, No. 2:13-cv-2192 JAM AC P (E.D. Cal. 2016):

It is well-established that the pleadings of pro se litigants are held to "less stringent standards than formal pleadings drafted by lawyers." Haines v. Kerner, 404 U.S. 519, 520 (1972) (per curiam). Nevertheless, "[p]ro se litigants must follow the same rules of procedure that govern other litigants." King v. Atiyeh, 814 F.2d 565, 567 (9th Cir. 1987), overruled on another

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