On June 23, 2022, Justice Cohen of the New York County Commercial Division issued a decision in Silverman v. Ying Ma, 2022 NY Slip Op. 31990(U), holding that LLCs and partnerships may not appear pro se in New York state court, explaining:
[T]he Verified Complaint was filed pro se by Silverman, individually and on behalf of Minerva (an LP) and Trigram (an LLC). It is well settled that corporations can only appear in court through an attorney, and may not proceed pro se. The statutory requirement that corporations and voluntary associations be represented by counsel in court proceedings extends to partnerships and limited partnerships. Silverman fails to show that he is a duly licensed attorney with the ability to sue on behalf of Minerva and Trigram. Accordingly, Silverman cannot pursue a claim (or a default judgment) on behalf of Minerva and Trigram and the motion for default judgment in favor of Minerva and Trigram must be denied on that ground alone.
(Internal quotations and citations omitted).