Although the decisions did not discuss the weight they gave to the leave to appeal in forma pauperis, they have been described as viewing "the orders permitting the appeals in forma pauperis as tantamount to the issuance of certificates of probable cause." Lara v. Nelson, 449 F.2d 323, 324 (9th Cir. 1971) (Kilkenny, J., concurring). Several factors make these decisions poor precedent, however.