Part I of this Note discusses the rise of pro se status in civil matters, specifically in immigration proceedings, and how courts and the legal community have responded with limited scope representation, including ghostwriting. Part II discusses in detail the controversy surrounding ghostwriting. It also illustrates how ghostwriting is, fortunately, beginning to gain acceptance. Lastly, Part III urges the acceptance of ghostwriting in immigration proceedings. It explains why ghostwriting is essential to immigrants and how the arguments put forth against the practice are not applicable to immigration proceedings.