Mark Labounty v. Stephen G. Adler, E. Carrillo, Walter A. Burdge, J. Grigioni, and All Program Committee Members

GEORGE C. PRATT, Circuit Judge:

Pro se plaintiffs create unique problems for federal courts. In recognition of this uniqueness, courts have developed some special strategies and guidelines to deal with such litigants. We are obliged to construe their pleadings and papers liberally. Haines v. Kerner, 404 U.S. 519, 92 S.Ct. 594, 30 L.Ed.2d 652 (1972). Incarcerated pro se litigants, since they cannot avail themselves of the freedom of other litigants, may “file” a notice of appeal simply by delivering it to prison authorities for mailing, rather than by actually filing it with the clerk of court…