RONALD B. LEIGHTON, District Judge.
THIS MATTER is before the Court on Defendant Lawn Limited's Motion to Dismiss for Lack of Personal Service [Dkt.# 8]. Lawn Limited claims it is a "Massachusetts Business Trust Organization," and it purports to enter a special notice of appearance through its "Special Executive Trustee," Donovan McDermott. McDermott also signed the Motion.
There is no indication that McDermott is an attorney, and he does not claim that he is representing Lawn Limited as an attorney. A business entity such as Lawn Limited cannot appear pro se in this Court.
Because a corporation is an artificial entity, necessarily its interests in a court proceeding must be represented by a person acting on its behalf. Representing another person or entity in court is the practice of law. To practice law, one must be an attorney. RCW 2.48.170. Thus Washington, like all federal courts, follows the common law rule that corporations appearing in court proceedings must be represented by an attorney.
There is a pro se exception to this general rule, under which a person "may appear and act in any court as his own attorney without threat of sanction for unauthorized practice." The pro se exception is, however, extremely limited and applies "only if the layperson is acting solely on his own behalf" with respect to his own legal rights and obligations. Cottringer v. State, Dep't of Employment Sec., 162 Wn.App. 782, 787-88, 257 P.3d 667, 669 (2011).
Lawn Limited's Motion to Dismiss [Dkt. # 8] is
IT IS SO ORDERED.