Pro Se Trustee Engaged in Unauthorized Practice of Law

Case summary for Elder Law Answers.The Texas Court of Appeals dismissed a trustee’s appeal because the trustee was not permitted to appear pro se in his capacity as a trustee, and in doing so, he engaged in the unauthorized practice of law. Almericas Veterans Mortgage Trust v. Brock & Scott, PLLC, No. 03-26-00461-CV, 2026 WL 1714996 (Tex. Ct. App. June 12, 2026).

In response to a trial court’s order against it, Almericas Veterans Mortgage Trust, represented by its pro se trustee, filed a notice of appeal. The Texas Court of Appeals notified the trustee that, under Rule 7 of the Texas Rules of Civil Procedure, he was not permitted to appear pro se in his representative capacity as a trustee. The court explained that Rule 7 allows individuals to represent themselves pro se to litigate their rights on their own behalf but not to litigate rights in a representative capacity. Only licensed attorneys are permitted to represent other parties under Texas law. Consequently, if a nonattorney trustee files documents on behalf of the trust, the trustee has engaged in the unauthorized practice of law.

Because no attorney filed an amended notice of appeal on the trust’s behalf, the court dismissed the appeal.

Read the full opinion.