Citizen's Guide to the Appellate Courts

July 2009

NEBRASKA Office of Public Information

I. INTRODUCTION his guide is designed to provide a self- rules established for the handling and progres- T represented person, or “pro se litigant,” with sion of cases through the appellate system. an overview of the Nebraska While it is our hope that the Guide will be a system. The creation of this material stems useful tool to assist the self-represented litigant from the need to ensure that the self-represented who wishes to pursue an appeal, this material litigant can effectively access the appellate does not replace the formal rules practice and system. By providing this information, we hope procedure of the Supreme Court and Court of the litigant will acquire a better understanding Appeals of the State of Nebraska which set forth of the structure and purpose of the appellate the Nebraska Court Rules of Appellate Practice system, how to effectively access the appellate and may be accessed via the Internet on the system, and how appeals are decided. Nebraska Judicial Branch Web site. Neither is Additionally, experience teaches that self- the Guide intended to be a substitute for the represented litigants may have unrealistic statutes and procedural rules which govern expectations about what the appellate courts appeals and which pro se litigants must consult can and will do, and that to their own detriment and follow—just as practicing lawyers are they do not always follow the procedural required to do.

II. APPEAL tated simply, an appeal is an attempt by a to “perfect” the appeal. “Perfect” simply means S litigant to secure a different result in a legal that the necessary steps have been accomplished controversy, civil or criminal, than that ren- on time so that the appeal is properly before the dered by the trial court or administrative agency appellate courts. Perfection of the appeal will be which has already decided the matter after a discussed in more detail shortly. trial or hearing. To appeal, the litigant must take certain steps within certain time limits in order

III. NEBRASKA APPELLATE SYSTEM e now turn to the two courts which make the two appellate courts, which is typically done W up the Nebraska Appellate System; by the Supreme Court “reaching down” into the however, the reader is cautioned that certain docket of the Court of Appeals to move cases to cases may require an intermediate appeal to the its own docket. The Court of Appeals can also district court before the case can be appealed to suggest that a case be moved to the Supreme the appellate system. For example, a misde- Court’s docket. See Neb. Ct. R. App. P. meanor criminal conviction in the county court § 2-102(C). The Supreme Court will move a must be appealed first to the district court. case, for example, if it believes that the issue Other than this cautionary note, intermediate presented is one which ultimately should be appeals to the district court are beyond the decided by the because scope of these materials, and the applicable of the nature of the case. Although the Supreme statutes and procedural rules governing these Court has an internal process to identify appeals cases must first be consulted. which should be moved to its docket, the statutes The Nebraska Supreme Court and the allow a litigant to file a written request with the Nebraska Court of Appeals comprise the Clerk of the Supreme Court/Court of Appeals appellate . The seven- asking that the Supreme Court allow an appeal member Supreme Court, headed by the Chief to bypass the Court of Appeals and be heard and Justice, is the State’s highest court and is often decided directly by the Nebraska Supreme called the court of last resort. The Supreme Court. See Neb. Ct. R. App. P. § 2-102(B). Court has the power to regulate the dockets of

Citizen’s Guide to the Nebraska Appellate Courts –http://www.supremecourt.ne.gov/self-help/ 1 The Nebraska Court of Appeals is a six- the trial court correctly applied the law, and judge court which includes a Chief Judge who when the trial court exercised discretion in its has administrative responsibilities for the decision, that such discretion was not abused. court. The Court of Appeals hears the majority The role of the Nebraska Supreme Court is of the appeals in Nebraska. All appeals except somewhat different. The Supreme Court tends those in which the death penalty or life impris- to decide cases involving issues which have a onment is imposed, those which challenge the broader impact in the legal system or are of constitutionality of a state statute, or limited great public interest. As a result, cases of this “original” actions as defined by the Nebraska nature are frequently moved from the docket of Constitution and by state statute are filed in the the Court of Appeals to the docket of the Court of Appeals. The mentioned exceptions Supreme Court to be decided. In this way, the are filed in the Nebraska Supreme Court and opinions of the Supreme Court assist in the processed from the outset in that court. development and clarification of the law for The fundamental difference in the roles of lawyers, trial court judges, and the public. the two appellate courts is that the Court of While handling fewer appeals than the Court Appeals is intended to be a court which han- of Appeals, the Supreme Court bears the addi- dles a high volume of cases. Its caseload typi- tional and substantial responsibility of oversee- cally involves cases in which only the parties ing the practice of law in the state as well as the involved are deeply interested. The basic func- administration of the entire judiciary of the tions of the Court of Appeals are to review State of Nebraska. decisions of the trial courts for errors in law or One result of this division of responsibility procedure and to correct those errors which between the two courts is that the six judges of have affected a litigant to his or her prejudice. the Court of Appeals decide the great majority Only errors which are prejudicial to a party or of the approximately 1,400 appeals filed each made a difference in the trial court’s decision year in Nebraska, but the cases decided by the are grounds for an appellate court to intervene. Supreme Court more often tend to have an In summary, in most of the appeals it hears, the impact which extends beyond the parties to the Court of Appeals looks primarily at whether case.

IV. SIGNIFICANCE OF APPELLATE COURTS’ STANDARD OF REVIEW term which is much discussed and used by something the litigants must determine for A the appellate courts is “standard of re-view.” themselves by research—for example, by look- Standards of review are well-established ing at the opinions of the appellate courts in guidelines or standards for the appellate courts’ similar cases. As a matter of routine, the appli- analysis of the trial court’s decision and have a cable standard of review is virtually always substantial impact on the outcome of the clearly and separately set forth in the opinions appeal. The standard of review might be of both appellate courts. thought of as the lens through which the appel- Although the reader is reminded that this late court looks at the evidence presented to the Guide is not intended to cover all standards of trial court, as well as the decision of that court. review for all types of cases, there are some A pro se litigant’s awareness of the standard of general principles which can be stated and will review for a particular type of case is critical perhaps help highlight the importance of the because it bears on the initial question of standard of review in the appellate process. whether an appeal should be filed, which nec- Appellate courts reach their own conclusions essarily involves consideration of the chances on questions of law. In other words, the appel- of obtaining a different result on appeal. late courts need not interpret a law, such as a It is beyond the scope and purpose of this statute, in the same way as the trial court. Guide to set forth the different standards of However, as to factual disputes (who said what review for the various types of cases. That is to whom), appellate courts normally do not

Citizen’s Guide to the Nebraska Appellate Courts – http://www.supremecourt.ne.gov/self-help/ 2 interfere with or change a trial court’s factual a divorce case or a case seeking an injunction, determinations unless the appellate court con- Nebraska law requires the appellate court to cludes that the trial court was “clearly wrong.” review the factual issues raised by the appel- When disputed questions of fact are reviewed lant’s assignments of error de novo (anew) on on appeal, an appellate court will rarely the record and reach its conclusions independ- “change” or reach a result different from the ent of the findings of the trial court. However, trial court’s factual findings. This is because even in such situations, the appellate court is the trial judge has the opportunity to actually often not inclined to reach different factual see and hear the witnesses testify, whereas the determinations, again because the trial court appellate court’s review is limited to the heard and saw the witnesses and believed one printed transcription of the testimony, some- witness over another. times referred to as the “cold record.” In other In conclusion, it is crucial that a self- words, the appellate process is normally not a represented litigant understand that the type of new trial, a retrial, or a second guessing of the case being appealed determines what the stan- trial court. dard of review will be for the appellate court’s Nonetheless, in certain types of cases the analysis of the case. Such understanding will appellate review is a “new trial,” called de novo assist the litigant in determining whether to review, but it is done by the appellate court appeal, in gauging the chances of success on using only the record of the evidence intro- appeal, and in determining what arguments duced in the trial court. As an example, in might be most persuasive to the appellate “equity cases” such as the property division in court.

V. HOW APPEALS REACH APPELLATE COURTS FROM TRIAL COURTS he process by which litigants present an discussed generally, it cannot be overempha- T appeal involves three basic steps: (1) per- sized that each of these steps is governed by fection of the appeal, (2) getting the trial record statutes and court rules which must be con- to the appellate court, and (3) writing and fil- sulted and followed. ing of briefs. While each of these steps will be

1. PERFECTION OF APPEAL

ot every decision of a trial court is imme- an order requiring a person to serve a sentence N diately appealable. Typically, the appellate in the penitentiary or pay a money judgment to courts do not become involved in a case until a another person, which order is properly signed final resolution has been reached in the trial by the judge, date-stamped, and filed by the court. (There are exceptions to this general rule clerk of the trial court, is normally a “final, which are beyond the scope of this Guide.) The appealable order.” Therefore, the first step in usual way of referring to this concept is that the appeal process is to ensure that the trial appeals can only be taken from “final, court’s order is a final, appealable order which appealable orders.” While it is not feasible to requires that it be signed by the judge and accurately and completely discuss the concept date-stamped and filed by the clerk of the trial of “final, appealable orders” in this Guide, a court. generalized example will perhaps be helpful. Assuming that the order is a final, appeal- An order of a trial court requiring the par- able order, the process of perfection of the ties to appear at a certain time and place for a appeal generally involves two basic require- pretrial conference is not a final, appealable ments. First, a written notice of appeal must be order and the appellate courts will not review prepared and filed with the clerk of the trial such a preliminary matter. On the other hand, court. There are several “special” types of

Citizen’s Guide to the Nebraska Appellate Courts – http://www.supremecourt.ne.gov/self-help/ 3 appeals, which will not be discussed here, notary public, setting forth financial circum- which require the filing of a different type of stances which show an inability to pay fees document to perfect the appeal. For example, and costs of the appeal. Either within the affi- an appeal from the Tax Equalization and davit or by a separate document, the person Review Commission requires the filing of a must also request that the court grant “indigent petition in the Court of Appeals among other status,” often formally referred to as “in forma stringent requirements for such an appeal. It is pauperis” (unable to pay costs of appeal for this reason that one must review the stat- because of poverty). Indigent status allows the utes, case law, and court rules to determine if a case to proceed without payment of the costs case is one of these “special” appeals. The of the appeal, including the cost of preparation notice of appeal must be filed within 30 days of of the trial court record, which will be dis- the trial court’s order. How those 30 days are cussed shortly in more detail. counted can vary with circumstances which are To summarize, an appeal is perfected from beyond the scope of this Guide. a final, appealable order by filing a notice of The second step in the perfection of the appeal and delivering the docket fee or pov- appeal must also be accomplished within erty affidavit and request for in forma pauperis those 30 days. This is the payment of a docket status to the clerk of the trial court within 30 fee (click here for current fee). If a person days of the trial court’s order from which the cannot afford to pay the fee, he or she can appeal is taken. Appeals that are not properly request from the trial court a waiver of the fee. perfected will be dismissed, often on the To do this, the litigant must file a poverty affi- appellate court’s own motion, for lack of juris- davit with the trial court, again within the 30- diction—which has the practical effect of day time limit, signed and sworn to before a leaving the trial court’s order unchanged.

2. SECURING RECORD FROM TRIAL COURT wo fundamental rules of appellate practice appellate court a record which supports the T come into play in this step. First, appellate party’s claim that the trial court was wrong in courts review only what happened in the trial some way and that the trial court’s decision court. Appellate courts do not hear new evi- must be changed. Therefore, as a result of dence or conduct their own trials. In other these rules, the “record” is of paramount words, appellate courts only look at what importance in any appeal. The “record” has occurred in the trial court (the “record”) when two parts: the transcript and the bill of excep- deciding the appeal. Second, an appealing tions, which shall be separately discussed. party has the responsibility to bring to the

(a) Transcript

he transcript consists of the pleadings of The transcript is obtained by filing in the T the parties, as well as the orders and judg- trial court which heard the case a written doc- ment of the trial court. From these documents, ument called a praecipe, which directs the the appellate court can determine what issues clerk of such court to prepare a transcript. The were heard by the trial court. Also, examina- praecipe should be filed at the same time the tion of the transcript enables the appellate notice of appeal is filed. The transcript shall courts to know the basic nature of the case, contain: (1) the pleadings upon which the case how the parties brought their issues to the was tried, as designated by the appellant; (2) attention of the court, who the parties are, and the judgment, decree, or final order sought to what preliminary and procedural orders the be reversed, vacated, or modified; and (3) the trial court made, as well as the final decision trial court’s memorandum opinion, if any. See made by the trial court. Neb. Ct. R. App. P. § 2-104. Section § 2-104 also provides for

Citizen’s Guide to the Nebraska Appellate Courts – http://www.supremecourt.ne.gov/self-help/ 4 the inclusion of other pleadings or orders in the tions of the record which are material to the transcript, as well as details of how the clerk of assignments of error.” The rule should be con- the trial court prepares the transcript. However, sulted before preparing the request for the tran- the rule specifically provides: “The appellant script because not every piece of paper filed in [person appealing] shall limit his or her request the trial court needs to be a part of the tran- for such additional material to only those por- script in the appellate court.

(b) Bill of Exceptions

he bill of exceptions contains the evidence time, the appellant shall deliver a copy of the T offered in the trial court, including testimony request to the court reporter so that he or she of witnesses and exhibits offered as evidence in knows what to prepare. See Neb. Ct. R. App. P. the trial court. It is a typed verbatim § 2-105. Section 2-105 states in part: transcription of what the parties, the witnesses, The request shall specifically identify the lawyers, and the judge said and did during each portion of the evidence and exhibits the trial court proceedings as prepared by the offered at any hearing which the party court reporter who recorded those proceedings. appealing believes material to issues to be As a cautionary note, the general rule is that if presented to the [appellate court] for review. something is not in the bill of exceptions, then The court reporter shall prepare only those it cannot and will not be considered by the portions specified in the re-quest for appellate court. However, not all court pro- preparation of the bill of exceptions. If the ceedings during the course of a case’s progress appellant intends to urge on appeal that a through the trial court will be necessary for the finding or conclusion is unsupported by the appeal. Thus, the parties can and should limit evidence or is contrary to the evidence, the the bill of exceptions only to those proceedings bill of exceptions must include all evidence which they believe are necessary for the appel- relevant to the finding or conclusion. late court to review the case. Doing so saves on Section 2-105 also contains specific the preparation costs for the record, saves work directions about other matters such as for the parties and the court, and improves effi- amendments to the bill of exceptions, the format ciency for all concerned. to be used by the court reporter, costs, and time The bill of exceptions is secured by the limits for preparation, et cetera. Because of the appellant filing with the office of the clerk of importance of a proper bill of exceptions to the the court from which the appeal is taken a appellate process, the self-represented litigant request to prepare a bill of exceptions at the must consult and follow § 2-105. same time the notice of appeal is filed. At that

3. WRITING AND FILING OF BRIEFS

he written brief is the time honored way by designed to enable the parties to present their T which the parties to an appeal present their appeal (or opposition to a party’s appeal) in a issues and positions to the appellate courts. At uniform, logical, clear, and understandable the outset, the pro se litigant must understand way, which in turn facilitates the that the Nebraska Supreme Court has estab- decisionmaking process of the court and lished precise and detailed rules about the ensures the efficient handling of the numerous preparation of briefs which encompass all appeals filed each year. aspects of the briefing process before both The pro se litigant must consult § 2-109 and appellate courts. See Neb. Ct. R. App. P. follow its provisions. This Guide will not § 2-109. A pro se litigant must be aware that attempt to summarize the provisions of the rule although self-represented, the appellate courts or emphasize one provision over another— insist on strict compliance with the various with one exception. Section 2-109(D) requires provisions of § 2-109. Section 2-109 is that the Citizen’s Guide to the Nebraska Appellate Courts – http://www.supremecourt.ne.gov/self-help/ 5 appealing party set forth “assignments of Assignments of error typically are limited error” in their brief. In the words of the rule: to those claims of error (mistakes) in the trial The brief of appellant, or plaintiff in an court which are of significance—meaning that original action, shall contain the following the alleged error made a difference in the out- sections under appropriate headings and in come of the case. The importance of proper the order indicated: assignments of error is emphasized by the long- . . . . standing rule of appellate practice which states e. A separate, concise statement of each that appellate courts will not address or decide error a party contends was made by the trial claims unless the alleged errors are both court, together with the issues pertaining to assigned in the brief and argued in the the assignments of error. Each assignment “Argument” section of the brief. The assign- of error shall be separately numbered and ments of error and accompanying arguments paragraphed, bearing in mind that focus the appellate court’s attention on a party’s consideration of the case will be limited to claim. The pro se litigant is once again directed errors assigned and discussed. The court to the precise provisions of § 2-109 (which may, at its option, notice a plain error not incidentally also governs briefing by lawyers) assigned. for guidance on proper briefing of the appeal.

VI. SUBMISSION OF APPEAL TO COURT FOR DECISION lthough both the Supreme Court and Court case comes up for argument. Decisions are not A of Appeals hear oral arguments monthly, at announced at argument. which counsel or self-represented litigants Whether a case will be orally argued, when orally present an argument before the court, not and in what order it will be argued in relation all appeals are eligible for oral argument. to other cases, and other details of the submis- Generally, the Supreme Court hears oral sion of the appeal are generally set out by court argument in a great majority of the appeals it rule. See Neb. Ct. R. App. P. § 2-111. This decides, whereas the Court of Appeals hears rule should be consulted for the particular argument in approximately half of the cases it details of this aspect of appellate procedure and decides. to deter-mine if a case is one in which there Oral argument is a formal proceeding, and may not be oral argument. parties appearing before the court are treated For a variety of reasons, not every appeal with respect and courtesy. Pro se litigants, like includes oral argument. A written motion and lawyers, are expected to discuss only the evi- supporting brief asking that the court summar- dence which is before the court in the bill of ily affirm the trial court, summarily dismiss the exceptions. Although the process is called appeal, or summarily reverse can be filed. See “argument,” parties are expected to be civil and Neb. Ct. R. App. P. § 2-107. There is no oral courteous to their opponents, the court, and argument on such motions except by order of court staff when presenting their case. The the court—which is unlikely. If such a motion argument should be limited to the assignments is granted, there will be no oral argument on of error discussed in the brief. Typically, the appeal and the appeal is decided, usually with- time allowed is 10 minutes per side, unless a out a formal opinion from the court. Section written request for additional time has been 2-107 sets forth the circumstances in which filed and granted by the court. Pro se litigants such motions may be filed and details the should understand that the judges hearing the nature and form of such motions and case will have read the briefs before argument supporting documents. The rule should be and have familiarity with the record. The judges consulted and closely followed by the pro se may have questions about the record or the litigant. argument. Some pro se litigants find it helpful Additionally, the court may, on its own to observe an argument session of the court, all through its internal review processes, deter- of which are open to the public, before their mine that oral argument is not necessary. For example, after examination of the briefs and

Citizen’s Guide to the Nebraska Appellate Courts – http://www.supremecourt.ne.gov/self-help/ 6 the record the court may conclude that the out- the Clerk takes action in this regard without come of the case is clear, and oral argument request from the parties. When the Clerk takes will be of no assistance to the court in reaching such action, the parties are fully informed by its decision. If the court determines not to hear the Clerk’s office, including information as to oral argument, the court will normally enter an when it is likely that the case will be orally order to that effect and the parties will be noti- argued—the “proposed call”—so that the par- fied by the Clerk of the Supreme Court and ties can advise the Clerk’s office of scheduling Court of Appeals. conflicts, for example. The Clerk’s office then As a practical matter, the Clerk undertakes advises parties of when their case will actually the vast majority of tasks associated with the be argued—“the call.” The proposed call and submission of cases for decision, including call for the Supreme Court and the Court of arranging all aspects of the oral argument ses- Appeals can be accessed on the Nebraska sion for each appellate court. Under § 2-111, Judicial Branch Web site.

VII. HOW APPELLATE COURTS DECIDE CASES he work of an appellate judge in deciding court and court staff. T an appeal revolves around reading briefs The six judges of the Court of Appeals and records, researching the law, and writing decide cases by sitting in two panels of three the opinion which decides the appeal and judges, the members of which rotate every sev- becomes the law of the case and binding on the eral months whereas, as a general rule, all trial courts. This work is done without commu- seven justices of the Supreme Court decide the nication with the parties or lawyers. Appellate matters before it. A case can be decided by a judges do not talk about cases that are before majority of the members of the court in which their court except with other members of the the case is heard.

1. APPELLATE OPINIONS

he decisions announced by written opin- category. Opinions which are “Not Designated T ions of the appellate courts are released to for Permanent Publication” are cases which the parties and the public on Friday morning have some degree of public interest or signifi- for the Supreme Court and on Tuesday morn- cance beyond that of the parties, but are not ing for the Court of Appeals. Earlier, some of intended to state new or unique principles of the differences in the work and type of cases law and therefore are not precedential for the heard by the two courts were discussed. Those trial courts. A “Memorandum Opinion and differences follow through in the opinions of Judgment on Appeal” is used by the Court of the two courts. Because the Nebraska Supreme Appeals in cases in which the court believes Court is our highest court, all of its opinions the case and its outcome are only of conse- constitute binding precedent. Therefore, not quence to the parties involved, and while pub- only does the opinion control the appeal, but lic record, such opinions are not released or the Supreme Court’s opinion is binding on all distributed beyond the parties and the trial other courts of the state, including the Court of court. Approximately 25 percent of the Court Appeals, and must be followed in the same or of Appeals’ opinions are of this type. similar circumstances. The opinions of the Nebraska Supreme In contrast, the Court of Appeals releases Court and the opinions of the Nebraska Court three types of opinions. However, only those of Appeals “Designated for Permanent “Designated for Permanent Publication” are Publication” become part of the fabric of law precedential and binding on the trial courts of of the state and are accessible by a variety of the state. Approximately 25 percent of the legal research methods. Finally, a significant opinions from the Court of Appeals fall in this number of the cases in the Court of Appeals are

Citizen’s Guide to the Nebraska Appellate Courts – http://www.supremecourt.ne.gov/self-help/ 7 decided by a simple order rather than a detailed support of the motion for rehearing. See Neb. opinion because the court has determined for Ct. R. App. P. § 2-113. Section 2-113 sets any number of reasons that an opinion will not forth in detail how such a motion is filed, its be of benefit. Nonetheless, such cases still go contents, and the response options for the through the same process of study and analysis opposing party. Such motions are not as cases which generate opinions. regularly filed and would not be granted Within 10 days of the release of either unless the party is able to demonstrate that the court’s opinion, a dissatisfied party may ask appellate court “missed something” either in for a rehearing by filing a motion and brief in the record or in the law it used to render its opinion.

2. PETITIONS FOR F URTHER REVIEW

nce the Court of Appeals has decided an Neb. Ct. R. App. P. § 2-102(F). While the O appeal, a litigant may petition the Supreme Court of Appeals decides approximately 1,200 Court for “further review” of that decision by cases per year, the Nebraska Supreme Court following a specific procedure, including the accepts only about 30 to 40 requests for further payment of a docket fee which is waived if a review of a decision of the Court of Appeals. litigant has previously been granted in forma Therefore, in the great majority of appeals, the pauperis status to appeal by the trial court. See decision of the Court of Appeals is the final decision.

VIII. CONCLUSION he justices of the Nebraska Supreme Court without a lawyer. If you are in doubt about how T and the judges of the Nebraska Court of to proceed, it is recommended that you consult Appeals recognize that most citizens are unfa- an attorney. miliar with the appellate process and that the This Guide is a product of the Nebraska process can be confusing to pro se litigants. Supreme Court Implementation Committee on The Nebraska Court Rules of Appellate Pro Se Litigation, Richard D. Sievers, Judge of Practice provide comprehensive direction on the Nebraska Court of Appeals, Chairperson, how to proceed in the appellate courts. This and is provided as a public service to self- Guide does not replace, substitute, or represented litigants. The Guide is being dis- supersede the Nebraska statutes, precedential seminated with the approval of the Nebraska appellate cases, or the Nebraska Court Rules of Supreme Court to assist pro se litigants. Appellate Practice which govern the appellate However, the Supreme Court makes no repre- process. This Guide is an attempt to make the sentation that the information in this Guide appellate process as understandable and will be appropriate for your circumstance. accessible as possible to every citizen of Again, it is recommended that any questions Nebraska who finds it necessary to resort to the you have regarding the information in this appellate courts and who proceeds Guide, or the proper means for appealing your case, should be directed to an attorney.

Citizen’s Guide to the Nebraska Appellate Courts – http://www.supremecourt.ne.gov/self-help/ 8

APPENDIX Links

Neb. Ct. R. App. P.§ 2-102(B) Neb. Ct. R. App. P. § 2-105 Neb. Ct. R. App. P. § 2-113 Neb. Ct. R. App. P. § 2-102(C) Neb. Ct. R. App. P. § 2-107 Supreme Court Call Neb. Ct. R. App. P. § 2-102(F) Neb. Ct. R. App. P. § 2-109 Court of Appeals Call Neb. Ct. R. App. P. § 2-104 Neb. Ct. R. App. P. § 2-111

Citizen’s Guide to the Nebraska Appelate Courts – www.nebraskacourt.com/selfhelp 9