What is the test for making a claim in a pro se proceeding?
MultiRegion, United States of America
The following excerpt is from Carter v. McDonald, No. 2:12-cv-00507-AC-P (E.D. Cal. 2014):
11. This claim was raised for the first time in the traverse. ECF No. 21 at 7. However, the court considers the issue out of an abundance of caution in light of the liberal construction of pro se proceedings. See Haines v. Kerner, 404 U.S. 519, 520 (1972).
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