What is the test for an appeal pro se from a dismissal of a complaint for lack of subject matter jurisdiction?

MultiRegion, United States of America

The following excerpt is from Spychala v. Secretary, Dept. of Health and Human Services, 872 F.2d 430 (9th Cir. 1989):

Spychala appeals pro se from the district court's dismissal of his complaint for lack of subject matter jurisdiction, based on the appellant's failure to exhaust his administrative remedies prior to seeking judicial review of the termination of his social security disability benefits. We review de novo, see Hironymous v. Bowen, 800 F.2d 888, 891 (CA9 1986), and we affirm.

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