## Facts

- The Housing Authority of the City of Orlando (the housing authority) filed an eviction action against tenant Loretta Quinn for nonpayment of rent.
- The eviction complaint was signed and filed on the housing authority’s behalf by its executive director.
- The executive director was not a licensed attorney.
- Quinn moved to dismiss, arguing that the housing authority was a corporate entity and therefore could not appear in court through a nonlawyer representative.
- The trial court denied Quinn’s motion to dismiss, allowing the eviction case to proceed.
- Quinn appealed the denial of her motion to dismiss.

## Issues

1. Whether a municipal housing authority, as a corporate entity, may file and prosecute an eviction action through a nonlawyer executive director rather than through licensed counsel.
2. If not, whether the proper remedy is dismissal of the eviction complaint without prejudice to refiling by an attorney.

## Decision

- The appellate court reversed the trial court’s order denying Quinn’s motion to dismiss.
- The court held that the housing authority, as a corporate entity, could not litigate through a nonlawyer director and that the director’s signing and filing of the complaint constituted unauthorized practice of law.
- The court remanded with directions to dismiss the eviction complaint without prejudice so the housing authority could refile through licensed counsel.

## Legal Principles

- A corporation or other corporate entity must appear in court through a licensed attorney and may not be represented by a nonlawyer officer, employee, or agent.
- Preparing, signing, and filing pleadings on behalf of a corporate entity, and prosecuting the case in court, are acts that constitute the practice of law.
- Public or governmental corporate bodies are subject to the same requirement of attorney representation in court as private corporations.
- When a corporate plaintiff initiates litigation through a nonlawyer representative, dismissal without prejudice is an appropriate remedy to permit refiling through counsel.

## Conclusion

Quinn holds that a municipal housing authority, treated as a corporate entity for litigation purposes, cannot pursue an eviction action through a nonlawyer executive director; because the complaint was filed by a lay representative, the trial court should have dismissed the action without prejudice so it could be refiled by licensed counsel.


Quinn v. Housing Authority of the City of Orlando, 385 So. 2d 1167 (1980)