Lorie Bernice Sharpe Trust v. Phung, 622 S.W.3d 929 (Tex. App.—Austin 2021, no pet. h.).


Pro Se

Trustee, a non-attorney, filed a notice of appeal from a trial court’s summary judgment. The appellate court explained to Trustee that a trustee may not appear pro se in a representative capacity because doing so is the unauthorized practice of law. Accordingly, the court advised Trustee that an attorney needed to file an amended notice of appeal to prevent the court from dismissing the appeal. Because no attorney did so, the court dismissed the appeal.


Moral:  A trustee cannot appear pro se in a representative capacity.