The following excerpt is from Hosein v. Burton, No. 2:19-cv-0403 KJM AC P (E.D. Cal. 2020):
1. Petitions filed while petitioner was proceeding pro se reflect application of the prison mailbox rule. See Houston v. Lack, 487 U.S. 266, 276 (1988) (establishing rule that a prisoner's court document is deemed filed on the date the prisoner delivered the document to prison officials for mailing).
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