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← 86 CALAPP2D 897 - Paradise v. Nowlin

Paradise v. Nowlin’s Empirical Analysis

1948

Citation profile

68
cited by 68 later decisions
12
states following
May 2010
most recently cited

2 district · 61 state decisions

How this case has been cited

Cited by 68 later decisions — most recently May 2010 · most notably 21 Cal. 3d 724 - Merco Construction Engineers, Inc. v. Municipal Court (1978), Union Savings Ass'n v. Home Owners Aid, Inc. (1970)

2 district · 61 state decisions — followed in 12 states

18019481950196019701980199020002010decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

Relationships

Relies on Osborn v. President Directors and Company of the Bank of the United States · Clark v. Austin · 76 Cal. App. 2d 379 - Prudential Insurance Co. v. Small Claims Court · Bennie v. Triangle Ranch Co. · 95 N.J. Eq. 12 - New Jersey Photo Engraving Co. v. Carl Schonert & Sons, Inc.

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 68 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “"The motion must be granted on the ground stated but there is another and more important reason for the dismissal of the appeal on the court's own motion, to wit, that the defendant corporation filed the notice of appeal in the superior court and its opposition to the dismissal in this court in propria persona. Such notice and opposition are void by reason of the corporation's lack of power to represent itself in an action in court. Defendant was represented by an attorney at the trial but his services apparently terminated with the entry of judgment in favor of plaintiffs. "A composite of the rule in the decided cases, overwhelmingly sustained by the authorities, may be thus stated: A natural person may represent himself and present his own case to the court although he is not a licensed attorney. A corporation is not a natural person. It is an artificial entity created by law and as such it can neither practice law nor appear or act in person. Out of court it must act in its affairs through its agents and representatives and in matters in court it can act only through licensed attorneys. A corporation cannot appear in court by an officer who is not an attorney and it cannot appear in propria persona. (Citing cases from Colorado, New York, Illinois, Indiana, Virginia, Missouri, New Jersey, Kansas, Minnesota and the U.S. Courts.) "The federal courts have held that the provisions in the statute that `the parties may plead and manage their own causes' or by attorney ( 28 U.S.C.”
    6 later decisions quote this exact passage

How this case has been treated — in progress

Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.