883 Keene Lane Trust v. JPMorgan Chase Bank, National Assocation
- Gregory Woods
- 1:25-cv-06689
- U.S. District Court · Southern District of New York
- 2
In 883 Keene Lane Trust v. JPMorgan Chase Bank, Judge Woods dismissed the appeal because nonlawyer Kenneth Lee could not represent the Trust.
883 Keene Lane Trust’s appeal was dismissed because Kenneth Lee, who filed it on the Trust’s behalf, was not a licensed lawyer. JPMorgan Chase Bank, National Association was the appellee.
What happened
In In re 883 Keene Lane Trust; Kenneth Lee v. JPMorgan Chase Bank, National Association, Kenneth Lee filed an appeal for the Trust after a bankruptcy court order. He identified himself as the Trust’s trustee, but he is not a lawyer.
The court explained that a trust or other entity must appear in federal court through a licensed attorney. A nonlawyer may represent himself, but may not represent another person or entity, including a trust.
Judge Gregory H. Woods dismissed Mr. Lee’s appeal and directed the clerk to close the case. The clerk was also directed to send Mr. Lee a copy of the order by certified mail.
The detailed version
- 883 Keene Lane Trust v. JPMorgan Chase Bank, National Assocation · No. 1:25-cv-06689
- Gregory Woods
- Aug. 14, 2025
Background
883 Keene Lane Trust filed a voluntary Chapter 7 bankruptcy petition on January 28, 2025. Kenneth Lee, described as a nonlawyer, filed an appeal on August 13, 2025, seeking review of a bankruptcy court order on the Trust’s behalf. His notice of appeal identified him as a “Trustee” of the Trust.
Legal standard
The court applied the rule that a trust or other fictional entity cannot appear in federal court without a licensed lawyer. A nonlawyer may represent himself or herself, but that permission does not extend to representing another person or entity. The court noted that this rule has also been applied to appeals from bankruptcy court orders in the Southern District of New York.
Ruling
Because Mr. Lee is not a lawyer and was attempting to represent the Trust in a representative capacity, the court concluded that he was not competent to represent the Trust in the appeal. Judge Gregory H. Woods dismissed the appeal. The court directed the clerk to close the case and to mail Mr. Lee a copy of the order by certified mail.
Disposition
The appeal was dismissed. The opinion does not state that the dismissal was with or without prejudice.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.