of appeal from dismissal of a habeas action would be considered filed. In Houston, the Court recognized that, “[u]nskilled in law, unaided by counsel, and unable to leave the prison, a pro se prisoner’s control over the processing of his notice necessarily ceases as soon as he hands it over[.]” Id. at 266. The Houston rationale was adopted by this court in Cooper and is helpful in analyzing the present case. Because we have recognized that a pro se litigant has initiated, or “filed,” his petition properly when he has completed everything within his control to deliver the actual petition to the court, we should not create a separate and somewhat contrary rule in a case in which a pro se litigant’s IFP status is denied subsequent to initiating the petition. Cf. Cooper, 70 F.3d at 381 (<HOLDING>). Recently, the Third Circuit applied Houston
holding that rule 56f applies to pro se litigants holding that although a pro se litigants pleadings are construed liberally a pro se litigant must still follow the same rules that govern other litigants including the requirement of constructing and supporting arguments with legal authority holding that although pro se litigants are entitled to liberal construction of their pleadings pro se litigants must follow procedural rules holding that a timebar should have the same effect on all pro se litigants because they are needful of a level playing field recognizing that although pro se litigants are not entitled to greater rights than represented litigants due process principles permit the imposition of a procedural bar only after consideration of the pro se litigants reasonable expectations about what had occurred