Is a pro se petitioner's lack of legal sophistication a basis for equitable tolling?
MultiRegion, United States of America
The following excerpt is from Colbert v. Miller, CASE NO. 12cv2941-LAB (BGS) (S.D. Cal. 2014):
But lack of sophistication is not a basis for tolling. See Raspberry v. Garcia, 448 F.3d 1150, 1154 (9th Cir. 2006) ("[A] pro se petitioner's lack of legal sophistication is not, by itself, an extraordinary circumstance warranting equitable tolling.")
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