State ex rel. Dillon v. Egnor
In State ex rel. Dillon v. Egnor, 188 W.Va. 221, 423 S.E.2d 624 (1992), the Court addressed the special contingencies of pro se litigation and observed that preservation of this fundamental right of self-representation compels a trial court to make "'reasonable accommodations' to assist the pro se litigant in negotiating the labyrinth of legal proceedings." Id. at 227, 423 S.E.2d at 630.
In syllabus point six of Dillon, this Court held that "where the litigants in a divorce case appear pro se, and the recommended order of the family law master is submitted to the circuit court without the filing of exceptions, the circuit court, and not the layman litigant, has the duty to prepare the final order." 188 W. Va. at 223, 423 S.E.2d at 626.