A large percentage of prisoners lose pro se actions for reasons other than prejudice. The most important reason is poor presentation of the case in written legal documents. Although many cases have controlling decisions supporting the inmate's side, the merit of the case is often lost in tangled intermixtures of facts, extraneous material, and unsupported assertions. Defeats of such appeals could be avoided through adequate training in argumentation. This training is equally important to the prisoner who is fortunate enough to have the professional services of a lawyer, since no one knows the facts of a prisoner's case as well as the prisoner. From intensive study of argumentation, the individual will learn how to develop an effective case presentation. The chapter provides one note.