Unreported / Non-Citable
Background
On August 21, 2026, Joseph O. Ogunrinu, a non-attorney, filed a complaint in Riverside County Superior Court on behalf of what appear to be three business entities — First California Financial Center, Global Visa & Immigration Services, and Ayinla Group — against AT&T Services Inc. and Does 1-10, asserting various state tort law claims. On September 21, 2026, the defendant removed the action to the U.S. District Court for the Central District of California.
The court observed that it has been established law for the better part of two centuries that a corporation may appear in the federal courts only through licensed counsel, citing Rowland v. California Men's Colony, 506 U.S. 194, 201-02 (1993), and Ninth Circuit precedent including In re Highley and United States v. High Country Broadcasting Co. The court further noted that Central District of California Local Rule 83-2.2.2 provides that only individuals may represent themselves pro se, and that no organization or entity of any kind — including corporations, limited liability companies, partnerships, limited liability partnerships, unincorporated associations, and trusts — may appear in any action or proceeding unless represented by an attorney permitted to practice before the court.
The Court’s Holding
Because Ogunrinu is not an attorney at law, the court determined that he may not bring and maintain the action on behalf of the three business entities. The court accordingly ordered Ogunrinu to show cause in writing no later than seven days from the date of the order why the action should not be dismissed without prejudice.
The court expressly warned that failure to timely file a response to the order would result in the action being dismissed without prejudice for failure to prosecute and comply with court orders, citing Federal Rule of Civil Procedure 41(b). The order was issued in chambers and signed by United States District Judge Kenly Kiya Kato.
Key Takeaways
- A non-attorney cannot file or maintain a lawsuit in federal court on behalf of a corporation, LLC, partnership, or other business entity.
- Central District of California Local Rule 83-2.2.2 explicitly prohibits entities from appearing pro se and requires representation by licensed counsel.
- The court issued an order to show cause giving the non-attorney filer seven days to explain why the case should not be dismissed without prejudice.
- Failure to respond to the order to show cause will result in dismissal without prejudice under Federal Rule of Civil Procedure 41(b) for failure to prosecute and comply with court orders.
- The ruling applies equally to removed actions originally filed in state court by a non-attorney on behalf of business entities.
Why It Matters
This order reinforces the long-standing rule that business entities must be represented by licensed attorneys in federal court and cannot proceed through non-attorney representatives, even at the initial filing stage. The court's use of an order to show cause — rather than immediate dismissal — provides a brief opportunity for the filer to secure counsel, but the warning of dismissal under Rule 41(b) underscores the consequences of non-compliance.
The decision serves as a reminder to would-be pro se entity representatives that removal to federal court does not cure the defect of unauthorized representation. It also illustrates how district courts apply both Supreme Court precedent and local rules to screen entity filings for unauthorized practice of law at an early procedural stage.