Lukunda Muhammad v. Joseph Shelton, 24-3178

Lukunda Muhammad, acting pro se, filed a complaint in December 2023 on behalf of a living trust in his name, seeking pension benefits allegedly withheld from him by various union and governmental defendants.
The District Court dismissed the case without prejudice, stating that a living trust (an artificial entity) cannot appear in court without licensed counsel, and ordered Muhammad to obtain counsel within 60 days to avoid dismissal with prejudice.
Muhammad did not obtain counsel but continued to file documents asserting sovereign citizen arguments and contesting the court's authority.
After Muhammad failed to respond to a dismissal notice for lack of prosecution and did not secure counsel, the court evaluated the Poulis factors and dismissed the action with prejudice in September 2024.
Muhammad appealed the dismissal, and the appellees sought summary affirmance in the Third Circuit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a living trust can appear pro se in federal court	Muhammad argued he could represent the trust himself	Defendants stated trusts require representation by counsel	Entities must have licensed counsel in court
Whether failure to obtain counsel warranted dismissal	Muhammad continued filings, denying court authority	Defendants argued dismissal was proper per court orders	Dismissal was warranted for failure to prosecute
Effect of sovereign citizen arguments on jurisdiction	Argued he was not subject to U.S. law/court authority	Defendants asserted court's jurisdiction was proper	Such arguments are frivolous; court had jurisdiction
Proper application of Poulis factors for dismissal	No meaningful contest on Poulis analysis	Defendants said factors supported dismissal	Poulis factors supported dismissal with prejudice

Rowland v. Cal. Men's Colony, 506 U.S. 194 (1993) (artificial entities must be represented by licensed counsel in federal court)
Link v. Wabash R.R. Co., 370 U.S. 626 (1962) (courts may dismiss cases for failure to prosecute)
Simbraw, Inc. v. United States, 367 F.2d 373 (3d Cir. 1966) (only licensed counsel may appear for artificial entities in court)