Mother Cannot Represent

A non-attorney parent cannot represent her children in a lawsuit, according to a decision of the United States Court of Appeals for the Ninth Circuit

La Dell Grizzell, acting on behalf of her minor children, sued the San Elijo Elementary School and the San Marcos Unified School District, alleging that the school violated the federal and state civil rights of her children. The district court dismissed the action without prejudice because of our long-established rule, dubbed the “counsel mandate,” that precludes Grizzell, as a nonlawyer, from representing her children pro se in pursuing their claims. Grizzell appeals the order dismissing her children’s claims. For the reasons that follow, we affirm.

(Mike Frisch)