In this publication one year ago,' it was argued that, although the pro se litigant generally is derided by parties, courts, and counsel alike, the procedures and general attitude of the United States Court of Appeals for the Second Circuit in dealing with such litigants effect, for the most part, considerable fairness in the treatment of pro se supplicants and their claims. One recent decision of the United States Supreme Court as well as the pro se proceedings in the Second Circuit during the 1974-75 term-a year in which more pro se litigants received relief than in any prior year in the history of the court-stimulates further examination of the plight and problems of the litigant who proceeds without counsel. Especially crucial in this inquiry is the ubiquitous frustration of the pro se litigant and the availability of counsel to alleviate some of this discontent.
Robbins, Ira and Herman, Susan, "Litigating without Counsel: Faretta or for Worse" (1976). Articles in Law Reviews & Other Academic Journals. 402.