pro_se -- as far as I can tell after a little looking, at least not directly/in so many words -- much to Scalia's dismay (e.g. http://www.msnbc.com/msnbc/the-supremes-divided-over-whether-actual-inn ) -- but once someone who is in fact innocent has been wrongly convicted, it typically is at least difficult to get out from under the conviction, as formalities tend strongly to trump substance -- see also e.g.:
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