In Re America West Airlines, Debtor. Seymour Licht v. America West Airlines Equity Security Holders Committee

Seymour Licht appeals pro se the Bankruptcy Appellate Panel’s (“BAP”) affirmance of the bankruptcy court’s order barring Licht, a non-attorney, from representing See More Light Investments, a business association in which Licht was the senior partner.

Corporations and other unincorporated associations must appear in court through an attorney. See C.E. Pope Equity Trust v. United States, 818 F.2d 696, 697-98 (9th Cir.1987); Church of the New Testament v. United States, 783 F.2d 771, 773-74 (9th Cir.1986); see also Eagle Assocs. v. Bank of Montreal, 926 F.2d 1305, 1309-10 (2d Cir.1991) (partnership not allowed to be represented by non-attorney partner).

In United States v. Reeves, however, we allowed a non-attorney partner to represent his interest in a partnership pursuant to Alaskan partnership statute. 431 F.2d 1187 , 1188 (9th Cir.1970). The Supreme Court in Rowland v. California Men’s Colony recently criticized our holding in Reeves and observed that “save in a few aberrant cases [including Reeves], the lower courts have uniformly held that 28 U.S.C. § 1654 , providing that ‘parties may plead and conduct their own case personally or by counsel,’ does not allow corporations,…