Copeland v. Interactive Brokers LLC

CourtDistrict Court, W.D. Oklahoma
DecidedSeptember 23, 2025
Docket5:25-cv-00637
StatusUnknown

This text of Copeland v. Interactive Brokers LLC (Copeland v. Interactive Brokers LLC) is published on Counsel Stack Legal Research, covering District Court, W.D. Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Copeland v. Interactive Brokers LLC, (W.D. Okla. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA

BRUCE COPELAND, derivatively on ) behalf of RBR INVESTMENTS, INC., ) ) Plaintiff, ) ) v. ) Case No. CIV-25-00637-JD ) INTERACTIVE BROKERS LLC, ) ) Defendant. )

ORDER

Before the Court are Plaintiff Bruce Copeland’s Motion for Certification of Interlocutory Order for Appeal (“Motion for Certification”) [Doc. No. 33], the Court’s Order directing Plaintiff Copeland to obtain counsel [Doc. No. 16], and Defendant Interactive Brokers LLC’s (“Interactive”) Motion to Dismiss (“Motion to Dismiss”) [Doc. No. 18]. Interactive filed a response brief (“Response”) [Doc. No. 37], opposing Copeland’s Motion for Certification. The Court previously issued a stay pending resolution of Copeland’s interlocutory appeal. [Doc. No. 34]. For the reasons stated below, the Court DENIES Copeland’s Motion for Certification and DISMISSES this case for Copeland’s failure to obtain counsel in compliance with the Court’s Order. The Court also DENIES AS MOOT Interactive’s Motion to Dismiss. I. BACKGROUND

On June 11, 2025, Copeland filed his complaint against Interactive, bringing an action “derivatively on behalf of RBR Investments, Inc.” [Doc. No. 1 at 1]. On June 12, 2025, the Court ordered Copeland to show cause why his complaint should not be dismissed for failure to comply with Local Civil Rule 17.1 and the longstanding prohibition on pro se litigants bringing actions on behalf of a corporation. [Doc. No. 4].

Copeland responded. [Doc. No. 6]. On July 18, 2025, the Court ordered Copeland to obtain counsel “no later than August 18, 2025” or face dismissal without prejudice [Doc. No. 16 at 4–5]. On August 15, 2025, Copeland filed two motions to stay this case while he appealed this Court’s July 18th Order to the United States Court of Appeals for the Tenth

Circuit. [Doc. Nos. 24, 26]. On September 8, 2025, the Court stayed proceedings in this case pending the outcome of Copeland’s interlocutory appeal [Doc. No. 34], and on that same day Copeland filed his Motion for Certification [Doc. No. 33]. On September 9, 2025, the Tenth Circuit dismissed Copeland’s appeal for failure to prosecute. [Doc. No. 36].

II. ANALYSIS

The Court had stayed proceedings in this case pending the outcome of Copeland’s appeal. As Copeland’s appeal has since been dismissed, the Court proceeds to adjudicate the above-mentioned motions. See [Doc. No. 34] (“The stay of this district court matter will automatically lift upon resolution of the interlocutory appeal by the Tenth Circuit, and this Court will take further action at that time.”). A. The Court declines to certify because no substantial ground for difference of opinion exists as to whether a pro se litigant may bring a derivative action.

Copeland seeks to appeal this Court’s determination that he may not pursue a derivative action pro se and that he must obtain counsel. Mot. Certification at 1. Copeland requests certification of this question under 28 U.S.C. § 1292(b). That statute states a district court shall indicate when it believes an otherwise non-appealable order “involves a controlling question of law as to which there is substantial ground for difference of opinion” and “an immediate appeal from the order may materially advance the ultimate termination of the litigation.” 28 U.S.C. § 1292(b). Upon such certification from the district court, the relevant court of appeals “may thereupon, in its discretion, permit an appeal to be taken from such order.” Id. It is well-established that corporations may appear only through counsel. Rowland v. Cal. Men’s Colony, 506 U.S. 194, 201–02 (1993). The real party in interest in a

derivative suit is the corporation, not the shareholder. Ross v. Bernhard, 396 U.S. 531, 538 (1970). An equally well-settled rule is that a pro se litigant only has standing to bring his own claims. LCvR17.1; 28 U.S.C. § 1654; Meeker v. Kercher, 782 F.2d 153, 154 (10th Cir. 1986). Moreover, the Tenth Circuit has refused to hear interlocutory appeals of orders compelling corporations be represented through counsel. Flora Constr. Co. v.

Fireman’s Fund Ins. Co., 307 F.2d 413, 413–14 (10th Cir. 1962). This rule isn’t arbitrary—it furthers legitimate policy concerns. “Unlike a personal suit, failure of the plaintiff to succeed in the action will result in a loss to the corporation because under the laws of many states . . . a corporation is obligated to indemnify the individual director defendants for their fees and expenses if the suit fails.” Phillips v. Tobin, 548 F.2d 408, 412 (2d Cir. 1976). So without the prohibition on pro se litigants, “‘a self-chosen representative and volunteer champion’” could cause “a substantial loss to

the corporation and . . . a decrease in the corporate assets and the value of the shares.” Id. (quoting Cohen v. Beneficial Indus. Loan Corp., 337 U.S. 541, 549–50 (1949)). In response, Copeland lists three Supreme Court cases that he claims create “tension” with the rule prohibiting pro se litigation of derivative actions. Mot. Certification at 3. The first, Ross v. Bernhard, 396 U.S. 531 (1970), extends the Seventh

Amendment right to a jury trial to derivative actions. But this case creates no tension with the general rule. As mentioned above, Ross v. Bernhard affirms the notion that the real party in interest in a derivative action is the corporation, not the shareholder. 396 U.S. at 538. The second case cited by Copeland, Kamen v. Kemper Financial Services, Inc.,

500 U.S. 90 (1991), held that demand futility pleading particularity rules operate with reference to state law. This has nothing to do with one’s ability to litigate a derivative action pro se. Likewise, Copeland’s third case—Cohen v. Beneficial Industrial Loan Corp., 337 U.S. 541 (1949)—dealt with a federal court’s application of state laws requiring plaintiffs

in a derivative action to provide security for attorney’s fees and costs. Cohen makes no suggestion that a shareholder has the right to litigate a derivative action without counsel. In sum, none of the three cases Copeland cites provide a “substantial ground for difference of opinion.” 28 U.S.C. § 1292(b).1 Here, Copeland styles this action as a derivative suit, and he avers the law allows

him to litigate this action pro se. Mot. Certification at 3. It does not. The above rules foreclose any possibility that Copeland presents a question on “which there is substantial ground for difference of opinion.” 28 U.S.C. § 1292(b). Because Copeland has not presented “substantial ground for difference of opinion” on this legal question,2 the Court denies his Motion for Certification.

B.

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