GILES
v.
RELEVANT MEDIA GROUP, INC.
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The district court struck a corporate defendant's pro se objection to a magistrate judge's report and recommendation, holding that a corporation cannot appear in federal court without licensed counsel and must retain an attorney within 20 days or face default judgment.
A corporation is an artificial entity that cannot appear pro se and must be represented by licensed counsel in federal court. Therefore, Defendant's pro se objection was stricken, and the corporation was granted 20 days to retain proper counsel.
“The rule is well established that a corporation is an artificial entity that can act only through agents, cannot appear pro se, and must be represented by counsel.”
Establishes the core legal principle that corporations cannot appear without licensed counsel in federal court.
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Join FLexlaw to unlock all legal intelligencePlaintiff filed a Motion for Default Judgment against Defendant Relevant Media Group, Inc. A Magistrate Judge issued a Report and Recommendation on th…
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Plaintiff moves to strike Defendant's objection (Dkt. 20) to the Report and Recommendation entered by Magistrate Judge Kidd (Dkt. 18) on Plaintiff's Motion for Default Judgment (Dkt. 15). (Motion, Dkt. 21.) Plaintiff argues that Defendant's objection is an unauthorized pro se filing of Defendant, a corporate entity. (Dkt. 21.) Upon consideration, the court agrees and Defendant's objection (Dkt. 20) is stricken.
“The rule is well established that a corporation is an artificial entity that can act only through agents, cannot appear pro se, and must be represented by counsel.” Palazzo v. Gulf Oil Corp., 764 F. 2d 1381, 1385 (11th Cir. 1985) (citation omitted); see also LaTele Television, C.A. v. Telemundo Commc’ns Grp., LLC, 9 F. 4th 1349, 1357 (11th Cir. 2021) (“Moreover, “[i]t has been the law for the better part of two centuries . . . that a corporation may appear in the federal courts only through licensed counsel.") (quoting Rowland v. Cal. Men's Colony, Unit II Men's Advisory Council, 506 U.S. 194, 201– 02 (1993)). Defendant, as a corporate entity, may therefore appear in this court only
through an attorney. As filed on the docket, Defendant's objection to Judge Kidd's Report and Recommendation appears to be an email to Judge Kidd from Mr. Cameron Strang, identified as “the CEO and founder" of Defendant, addressing several factual issues in this matter and Plaintiff's potential damages. (Dkt. 20.) There is no indication that Mr. Strang is an attorney, or that he is appearing in this matter as counsel for Defendant, a corporate entity.
Accordingly:
1. Plaintiff's Motion to Strike Pro Se Objection to Report and Recommendation (Dkt. 21) is GRANTED.
2. Defendant's objection to Judge Kidd's Report and Recommendation (Dkt. 20) is STRICKEN.
3. Defendant is granted 20 days to retain counsel and to properly appear in this matter. See Palazzo, 764 F. 2d at 1386 ("The record is clear that the court below was more than accommodating in urging proper representation of the corporate claims."). After that time, the court will take the Report and Recommendation (Dkt. 18) and Plaintiff's Motion for Default Judgment (Dkt. 15) under consideration.
ORDERED in Orlando, Florida, on March 28, 2024.
JULIE S. SNEED
UNITED STATES DISTRICT JUDGE
Copies furnished to: Counsel of Record Unrepresented Party: Relevant Media Group, Inc. d/b/a Relevant Magazine c/o Cameron Strang 3720 Lake Sarah Drive, Suite B Orlando, FL 32804
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Citator
Authorities Cited
- Palazzo v. Gulf OIL Corp., 764 F.2d 1381 (11th Cir. 1985)
- Rowland v. California Men's Colony, 506 U.S. 194 (U.S. 1993)
- Latele Television v. Telemundo Commc'ns Grp., LLC, 9 F.4th 1349 (11th Cir. 2021)