Enduring Love International Church v. Williams, 2:23-cv-01120

Plaintiffs, including Enduring Love International Church and several individuals acting pro se, filed a lawsuit in the Eastern District of Wisconsin and paid the filing fee.
Several defendants were dismissed early in the case, leaving Judge Williams, Judge Borowski, Clerk Hodges, and Officer Nardi as the remaining defendants.
The court previously warned the plaintiffs that Enduring Love International Church, as an entity, must be represented by a licensed attorney and that proper service of process on the remaining defendants was required.
Plaintiffs failed to provide proof of proper, timely service on the remaining defendants despite a court-ordered extension and multiple warnings.
A premature appeal to the Seventh Circuit was dismissed for lack of jurisdiction, as no final judgment had been entered by the district court.
Upon return of jurisdiction, the district court found: (1) no attorney appeared for Enduring Love International Church; (2) no proper service on defendants; and (3) ordered dismissal without prejudice due to lack of personal jurisdiction and failure to comply with court orders.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether service on remaining defendants was proper and timely	Plaintiffs claimed their efforts sufficed, focusing on equity and merits	Defendants argued service was improper or not demonstrated	No proof of proper, timely service; dismissal for lack of jurisdiction
Whether Enduring Love International Church can appear pro se	Plaintiffs submitted filings as the entity pro se	Court and precedent require attorney representation for entities	Dismissed church as plaintiff for lack of counsel
Whether default judgment could be entered vs. unserved defendants	Plaintiffs sought default judgment	Defendants not properly served; no appearance entered	Denied default judgment; no service = no jurisdiction
Whether case should be dismissed or allowed to proceed after failure to follow orders	Plaintiffs urged case be allowed to continue; cited equity	Defendants made no appearance (lack of service)	Case dismissed without prejudice for failure to comply

Rowland v. Cal. Men’s Colony, 506 U.S. 194 (entities must be represented by licensed counsel in federal court)
United States v. Hagerman, 545 F.3d 579 (entity representation by counsel requirement)
Muzikowski v. Paramount Pictures Corp., 322 F.3d 918 (entities cannot proceed pro se)
Griggs v. Provident Consumer Disc. Co., 459 U.S. 56 (notice of appeal divests district court of jurisdiction)