Christ Commanded v. Bureau of Land Management-Nevada State Office

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA * * * Christ Commanded Case No. 2:25-cv-1983-GMN-BNW Plaintiff, v. Bureau of Land Management-Nevada State Office

Defendant.

Before the Court is Plaintiff’s application to proceed in forma pauperis (IFP). ECF No. 4. Rev. Dr. Jake Beard appears to have submitted the application to proceed in forma pauperis on behalf of Plaintiff Christ Commanded, a church. See id. Congress intended the statute authorizing IFP to be applicable only to natural persons rather than to corporate entities such as a church. See Rowland v. California Men’s colony, Unit II Men’s Advisory Council, 506 U.S. 194, 203 (1993). Here, Rev. Beard appears to be representing Christ Commanded, a non-profit corporate entity, as its president and authorized signatory. ECF No. 1-1. Since only natural persons can proceed IFP, this Court denies Plaintiff’s application with leave to refile. Additionally, this Court notes that corporate entities may appear in federal court only with a licensed attorney. In re Am. W. Airlines, 40 F.3d 1058, 1059 (9th Cir. 1994). “The rule requiring corporations to have counsel rather than to proceed in litigation pro se applies even if the corporation is a non-profit corporation.” Her Oceans v. Cmty. Outreach Behav. Servs., Inc., No. 1:21-cv-00198-DCN, 2021 WL 3172914 at *1 (D. Idaho, July 27, 2021). Because non-profit corporate entities must be represented by a licensed attorney to appear in federal court, Rev. Beard, who is not a licensed attorney, may not represent Christ Commanded. IT IS THEREFORE ORDERED that Plaintiff’s Motion/Application for Leave to Proceed In Forma Pauperis (ECF No. 4) is DENIED without prejudice. ] IT IS FURTHER ORDERED that if Rev. Beard wishes to refile the application to proceed IFP on his own behalf, he must refile the application by December 4, 2025. DATED: November 4, 2025 Kg bein ban BRENDA WEKSLER □ UNITED STATES MAGISTRATE JUDGE 1]