Wyoming Financial Group v. Smith
Wyoming Financial Group, Inc. v. Sheri Smith, Donte Powell, Dane Devogelare, Harrishana Aleena Griffin, Bank of America N.A., JP Morgan Chase Bank N.A., and BMO Bank N.A.
- Vargas
- 1:25-cv-09622
- U.S. District Court · Southern District of New York
- 2
In Wyoming Financial Group v. Smith, Judge Vargas dismissed the action without prejudice because the corporation could not litigate without counsel and had 30 days to retain one.
Wyoming Financial Group, Inc.’s action against Sheri Smith, Donte Powell, Dane Devogelaere, Harrishana Aleena Griffin, Bank of America N.A., JP Morgan Chase Bank N.A., and BMO Bank N.A. was dismissed without prejudice; the court did not decide the underlying claims.
What happened
Wyoming Financial Group, Inc. sued Sheri Smith, Donte Powell, Dane Devogelaere, Harrishana Aleena Griffin, Bank of America N.A., JP Morgan Chase Bank N.A., and BMO Bank N.A. The company brought the action without a lawyer.
The court explained that corporations and other artificial entities cannot represent themselves in federal court. The opinion also noted that Tasheeme M. Goings signed the complaint, although Goings was not listed as a plaintiff, and did not submit an application to proceed without paying filing fees or pay the filing fees.
Judge Jeannette A. Vargas dismissed the action without prejudice to Wyoming Financial Group, Inc. retaining counsel within 30 days of the order. The court did not decide the underlying claims.
The detailed version
- Wyoming Financial Group v. Smith · No. 1:25-cv-09622
- Vargas
- Dec. 3, 2025
Background
Wyoming Financial Group, Inc. brought the action against the named individual and bank defendants without a lawyer. The opinion states that Tasheeme M. Goings signed the complaint, but Goings was not listed as a plaintiff. The court also noted that Goings did not submit an application to proceed without paying filing fees or pay the filing fees.
Issue
The issue was whether Wyoming Financial Group, Inc. could litigate in federal court without a licensed attorney. The court explained that corporations, nonprofit organizations, partnerships, associations, and other artificial entities cannot proceed on their own behalf without counsel.
Ruling
The court dismissed the action without prejudice to Wyoming Financial Group, Inc. retaining counsel within 30 days of the order. “Without prejudice” means the dismissal did not bar the stated opportunity to retain counsel and proceed as permitted by the court. The court did not reach the merits of Wyoming Financial Group, Inc.’s claims against any defendant.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.