SHAYLA ROBINSON
v.
GFB RESTAURANTS, LLC; HEMINGWAYS HOSPITALITY, LLC; LOUIS GOETZ; BRUNILDA KHOKA; FLORENCA XHOKA; AND GERTI XHOKA
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The District Court addressed a procedural violation in which a pro se defendant attempted to represent a corporate defendant in a case management conference. The court struck the filed case management report and ordered the corporate defendant to secure counsel, citing the well-established rule that corporations cannot appear pro se.
A pro se party cannot legally represent a corporation. Corporations are artificial entities that can only act through agents, cannot appear pro se, and must be represented by counsel, even when the pro se individual is the corporation's president and major stockholder.
[1] A pro se party cannot legally act on behalf of another defendant.
[2] A corporation, as an artificial entity, can only act through agents and cannot appear pro se, thus requiring representation by counsel.
Previewing 2 of 5 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“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... The general rule applies even where the person seeking to represent the corporation is its president and major stockholder.”
Establishes the controlling principle that corporations cannot appear pro se and must be represented by counsel, regardless of the individual's relationship to the corporation.
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Join FLexlaw to unlock all legal intelligenceDuring a planning conference for the case management report, pro se Defendant Louis Goetz attended purporting to represent both herself and Hemingways…
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On January 6, 2026, this Court gave parties an extension to submit a Case Management Report no later than January 13, 2026, Doc. 27. On January 14, 2026, the parties submitted a Case Management Report, Doc. 31. The Report states that “[t]he parties conducted the planning conference” in which pro se Defendant Louise Goetz attended “on behalf of herself and Hemingways Hospitality, LLC.” Id. at 1. A pro se party cannot legally act on behalf of another defendant. See Palazzo v. Gulf Oil Corp., 764 F. 2d 1381, 1385 (11th Cir. 1985) (“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 . . . The general rule applies even where the person seeking to represent the corporation is its president and major stockholder.”).
Accordingly, the following is ORDERED:
1. The Clerk shall STRIKE the (Doc. 31) Report from the Record.
2. To proceed in this action, Defendant Hemingways Hospitality, LLC, must secure counsel. Failure to do so will permit Plaintiff Robinson to move for default.
3. The parties shall file an amended Case Management Report no later than February 6, 2026.
4. The Court reminds Lead Counsel of its duties when interacting with unrepresented parties.
ORDERED in Tampa, Florida, on January 16, 2026.
Kathryn Kimball Mizelle United States District Judge
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