Willis v. Sakayama
- Vyskocil
- 1:22-cv-01208
- U.S. District Court · Southern District of New York
- 2
In Willis v. Sakayama, Judge Vyskocil ordered counsel for the corporate plaintiff by March 15 or warned the complaint would be dismissed.
Karen L. Willis and the corporate entities identified as Harlem West Entertainment and Harlem West Music Group were required to obtain licensed counsel or face dismissal of the complaint.
What happened
In Willis v. Sakayama, Karen L. Willis sued Bob Sakayama and TNG/Earthling, Inc., while proceeding without a lawyer. The complaint said Willis did business for Harlem West Entertainment and Harlem West Music Group, which she described as the exclusive licensee for the Village People.
Judge Vyskocil explained that a corporation cannot represent itself in federal court and must appear through a licensed lawyer. The judge also said that a person without a law license cannot represent another person or entity.
The court ordered the plaintiff to retain a lawyer by March 15, 2022. Judge Vyskocil warned that failing to do so would result in dismissal of the complaint.
The detailed version
- Willis v. Sakayama · No. 1:22-cv-01208
- Vyskocil
- Feb. 15, 2022
Background
Karen L. Willis filed the complaint while proceeding without a lawyer. The complaint stated that she did business on behalf of Harlem West Entertainment and Harlem West Music Group, collectively called “Harlem West,” and that Harlem West was the exclusive licensee for the Village People. The defendants are Bob Sakayama and TNG/Earthling, Inc., identified in the opinion as a New York corporation.
Court’s reasoning
The court held that Harlem West, as a corporate entity, could not proceed without licensed counsel. The court also explained that Willis, as a person proceeding without a lawyer, could not act on behalf of another person or entity. The opinion stated that a corporate plaintiff that does not appear through counsel may be dismissed for failure to prosecute, meaning failure to move the case forward.
Order
The court ordered the plaintiff to retain counsel on or before March 15, 2022. It ordered that failure to do so would result in dismissal of the complaint. The Clerk of Court was requested to mail the order to Willis at the address of record.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.