Kevin Yeung v. Shannon Humphrey

Whether the Fourteenth Amendment required a state court to afford an unrepresented civil litigant a further opportunity to submit competent expert support before entering summary judgment, where the litigant had notice of evidentiary objections, filed posthearing custodian affidavits concerning two of the three reports but no affidavit from the third author, the state appellate court found no demonstrated request for additional time to cure, and state law made supplementation discretionary.