Is a pro se petitioner's lack of legal sophistication sufficient to cause equitable tolling?

MultiRegion, United States of America

The following excerpt is from Garcia v. Grounds, No. CIV S-12-1060 KJM GGH P (E.D. Cal. 2013):

Finally, "a pro se petitioner's lack of legal sophistication is not, by itself, an extraordinary circumstance warranting equitable tolling." Rasberry v. Garcia, 448 F.3d 1150, 1154 (9th Cir. 2006).

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