Whether when granting a pro se litigant leave to amend the complaint, a district court must identify the complaint deficiencies so that the pro se litigant can use the opportunity to amend effectively

QUESTION PRESENTED A district court granted a pro se litigant leave to amend her complaint without notice of complaint deficiencies. Unable to identify the deficiencies herself, the pro se litigant repeated previous errors and the district court denied her further leave to amend. The question presented is: , Whether when granting a pro se litigant leave to amend the complaint, a district court must identify the complaint deficiencies so that the pro se litigant can use the opportunity to amend effectively as held by the Second, Seventh, Eights, and Ninth Circuits. : ili ,