In your first paragraph do you refer to prisoners?
I am not familiar with that case.
The court has recognized a role for jail house lawyers. So i guess you have to give up some canteen to get your filing done. Or find pro-bono.
Lawful incarceration brings about the necessary withdrawal or limitation of many privileges and rights, a retraction justified by the considerations underlying our penal system. Among those so limited is the otherwise unqualified right given by § 272 of the Judicial Code, 28 U.S.C. § 394, to parties in all the courts of the United States to "plead and manage 286*286 their own causes personally."
See also:
These are landmark Habeas cases.