Pierce County Republican Party v. Crowl
3:25-cv-05251
W.D. Wash.Jul 10, 2025Background
- The Pierce County Republican Party (Plaintiff) sought to have Defendant Eric Eugene Crowl and his nonprofit entities—"Pierce County Republican Party" and "Washington47 PAC"—reimburse service fees and be found in default for failure to properly respond to the suit.
- Plaintiff moved for an order requiring Crowl to reimburse service costs under Fed. R. Civ. P. 4(d)(2) and for default against Crowl and the nonprofit entities.
- Defendants did not respond to the motion for service fee reimbursement within the court-mandated timeline.
- Crowl, proceeding pro se, filed a Rule 12(b)(6) motion to dismiss the day after his response was due; however, he is not an attorney and cannot represent the nonprofits.
- The court considered the failure to respond an admission of Plaintiff’s motion’s merit regarding service fees.
- The court evaluated whether Crowl could represent the entities and whether default was appropriate for each defendant.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Reimbursement for service and attorney fees | Crowl should pay for costs due to his non-compliance | No response | Granted; Crowl ordered to pay $125 service and $140 legal fees. |
| Default as to individual defendant Crowl | Crowl missed deadline to answer or defend | Filed motion one day late | Denied; his belated filing suffices for his personal default. |
| Default as to nonprofit entities (representation issue) | Crowl cannot represent nonprofits pro se | Crowl attempted pro se defense | Granted; default entered against corporations for lack of counsel |
| Court’s response to non-noted motions/notices | Crowl filed improper "notices" and "requests" | Filed various informal filings | Denied; Court acts only on properly noted motions. |
Key Cases Cited
- Russell v. United States, 308 F.2d 78 (9th Cir. 1962) (A non-attorney may not represent anyone other than himself in federal court)
- Collins v. O'Brien, 208 F.2d 44 (D.C. Cir. 1953) (Same rule for corporate representation); cert. denied, 347 U.S. 944 (1954)
- McShane v. United States, 366 F.2d 286 (9th Cir. 1966) (The pro se privilege is personal and does not extend to representation of others)