Zonis v. Grubman
- Jesse Furman
- 1:20-cv-07181
- U.S. District Court · Southern District of New York
- 5
In Zonis v. Grubman, Judge Furman ruled that Michael Christy may not represent Peter Zonis in federal court.
Peter Zonis may not be represented in this federal case by Michael Christy. Christy was also cautioned about potentially unauthorized legal practice in New York.
What happened
Zonis v. Grubman concerns Michael Christy’s involvement in the case as an assistant and paralegal to Peter Zonis, who was representing himself.
The court explained that federal law permits only a licensed attorney to represent another person, or a person to represent himself. The court also cautioned that Christy’s legal advice and help drafting documents might be unlawful practice of law in New York.
Judge Jesse M. Furman ruled that Christy may not appear for Zonis or otherwise represent him in the case. The clerk was directed to mail a copy of the order to Zonis.
The detailed version
- Zonis v. Grubman · No. 1:20-cv-07181
- Jesse Furman
- Jan. 4, 2021
Background
The court received a letter from Michael Christy concerning his involvement in the case as an assistant and paralegal to Peter Zonis. The order refers to Zonis as representing himself. The opinion does not describe the full contents of Christy’s letter in the readable portion provided.
Legal framework
The court relied on 28 U.S.C. § 1654, which allows two forms of appearance in federal court: representation by an attorney admitted to practice law and self-representation. Citing Second Circuit decisions, the court stated that an individual who is not licensed as an attorney may not appear on another person’s behalf.
Ruling
The court ruled that Christy may not appear on behalf of Zonis or otherwise represent him in connection with the case. The court expressed sympathy for Zonis if he was limited in the ways Christy’s letter suggested, but that sympathy did not change the representation rule.
Separately, the court cautioned Christy that providing legal advice and assistance drafting legal documents might constitute the unauthorized practice of law, which the court stated is unlawful in New York under N.Y. Judiciary Law § 478. The clerk was directed to mail a copy of the order to Zonis.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.