9th Circuit upholds dismissal of civil rights and antitrust lawsuit against LA's water utility, ruling…
Brown v. Los Angeles Department of Water and Power
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9th Circuit upholds dismissal of civil rights and antitrust lawsuit against LA's water utility, ruling the company had to have a lawyer and the individual plaintiff lacked standing.
Why it matters
The Ninth Circuit affirmed the dismissal of a lawsuit brought by Marvin Brown and his company, Maverick Consulting Group, against the Los Angeles Department of Water and Power and others. The court found that Maverick, as a company, was required by law to be represented by an attorney and was properly dismissed when it failed to get one. Brown himself admitted he lacked standing to sue on behalf of the company, and he forfeited his federal claims by not addressing them in his appeal.
Who it affects
This ruling most directly affects business owners and companies who try to file federal lawsuits without an attorney, reminding them that companies must be legally represented by a licensed lawyer. It also reinforces that individual owners generally cannot step in to pursue claims on behalf of their business if they were not personally and independently harmed.
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Decision issued Jul 13, 2026
Unpublished opinion
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- Decision issued Jul 13, 2026Unpublished opinion
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Jul 13, 2026 · Unpublished opinion
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DEEPER READ
Marvin Brown and his company, Maverick Consulting Group, filed a lawsuit against the Los Angeles Department of Water and Power, the Los Angeles Office of the City Attorney, and Pandora Consulting Associates. Their claims included civil rights violations under federal law, a federal antitrust claim under the Sherman Act, and various California state law claims. They initially filed the case without lawyers, representing themselves. The central problem for the case was that corporations and other business entities, including limited liability companies like Maverick, are not allowed to represent themselves in federal court. They must have a licensed attorney appear on their behalf. The district court gave Maverick thirty days to hire a lawyer or face dismissal. Maverick did not hire a lawyer, did not explain why, and did not ask for more time. The district court dismissed Maverick from the case. With Maverick gone, Brown was the only remaining plaintiff. However, Brown himself conceded on appeal that he lacked legal standing to sue. Under established law, a shareholder or owner generally cannot sue to recover for injuries suffered by their company unless they were independently and directly harmed themselves. Because Brown lacked standing and Maverick had been properly dismissed, the entire lawsuit was properly thrown out. The court also noted that Brown failed to challenge the dismissal of his specific federal claims in his opening appeal brief, which meant those arguments were considered forfeited under court rules. With all federal claims gone, the court also declined to exercise jurisdiction over the remaining state law claims, which is standard practice when federal claims are dismissed. The court was unanimous and there was no dissent noted in the opinion.
CITATION AND RECORD
Record source: CourtListener
NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS JUL 13 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT MARVIN BROWN; MAVERICK No. 25-790 CONSULTING GROUP, LLC, D.C. No. 2:24-cv-05152-SVW-JPR Petitioners - Appellants, v. MEMORANDUM* LOS ANGELES DEPARTMENT OF WATER AND POWER; LOS ANGELES OFFICE OF THE CITY ATTORNEY; PANDORA CONSULTING ASSOCIATES, LLC, Respondents - Appellees. Appeal from the United States District Court for the Central District of California Stephen V. Wilson, District Judge, Presiding Submitted July 9, 2026** Pasadena, California Before: RAWLINSON and SANCHEZ, Circuit Judges, and FITZWATER, District Judge.*** * This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2). *** The Honorable Sidney A. Fitzwater, United States District Judge for the Northern District of Texas, sitting by designation. Marvin Brown and his company, Maverick Consulting Group, LLC (“Maverick”), appeal the district court’s dismissal of their action against the Los Angeles Department of Water and Power (“LADWP”) and Pandora Consulting Associates, LLC (“Pandora”) under 42 U.S.C. §§ 1981 and 1983, Section 1 of the Sherman Act, and California law. We have jurisdiction under 28 U.S.C. § 1291. We affirm.1 1. We review for abuse of discretion a district court’s dismissal for failure to comply with a court order. Pagtalunan v. Galaza, 291 F.3d 639, 640 (9th Cir. 2002). The district court did not abuse its discretion in dismissing Maverick after it failed to comply with the court order to retain counsel within thirty days. “It is a longstanding rule that ‘[c]orporations and other unincorporated associations must appear in court through an attorney.’” D-Beam Ltd. P’ship v. Roller Derby Skates, Inc., 366 F.3d 972, 973–74 (9th Cir. 2004); see also C.D. Cal. Loc. R. 83-2.2.2 (“No organization or entity of any other kind (including . . . limited liability corporations . . . ) may appear in any action or proceeding unless represented by an attorney permitted to practice before this Court.”). “Failure to follow a district court’s local rules is a proper ground for dismissal.” Ghazali v. Moran, 46 F.3d 52, 53 (9th Cir. 1995) (per curiam). After Brown and 1 Brown’s request for judicial notice is denied, “as the materials contained therein are not relevant to the disposition of this appeal.” Cuellar v. Joyce, 596 F.3d 505, 512 (9th Cir. 2010). 2 25-790 Maverick filed this action pro se, the district court gave Maverick thirty days to retain counsel in compliance with local rule or be dismissed. Maverick did not comply, explain its failure to comply, or seek an extension to retain counsel. The district court dismissed Maverick and did not grant leave to add Maverick back in any subsequent order.2 2. Brown concedes on appeal that “[he] does not have standing.” See Shell Petroleum, N.V. v. Graves, 709 F.2d 593, 595 (9th Cir. 1983) (“[A] shareholder does not have standing to redress an injury to the corporation” unless it is “injured directly and independently of the corporation.”). Because the district did not abuse its discretion in dismissing Maverick, and Brown as the only remaining plaintiff lacks standing, the district court properly dismissed this case. 3. The district court also correctly held that Brown failed to state a claim for his federal claims. We review a grant of motion to dismiss for failure to state a claim de novo. Silvas v. E*Trade Mortgage Corp., 514 F.3d 1001, 1003–04 (9th Cir. 2008). Brown did not address the district court’s dismissal of his federal claims on the merits in his opening brief, so any challenge is forfeited. Orr v. 2 Contrary to Brown’s assertion, “the due process right to retain counsel in civil cases appears to apply only in extreme scenarios where the government substantially interferes with a party’s ability to communicate with his or her lawyer or actively prevents a party who is willing and able to obtain counsel from doing so.” Adir Int’l, LLC v. Starr Indem. & Liab. Co., 994 F.3d 1032, 1039–40 (9th Cir. 2021). Brown does not demonstrate any such extraordinary circumstances. 3 25-790 Plumb, 884 F.3d 923, 932 (9th Cir. 2018) (“The usual rule is that arguments . . . omitted from the opening brief are deemed forfeited.”). Having “dismissed all claims over which it has original jurisdiction,” the district court properly “decline[d] to exercise supplemental jurisdiction” over Brown’s state law claims.3 28 U.S.C. § 1367(c)(3). AFFIRMED.4 3 The district court does not have diversity jurisdiction because all remaining parties are from California. 28 U.S.C. § 1332. 4 Brown argues that the district court erred by failing to convert the motion to dismiss into a motion for summary judgment. We are not persuaded because the district court did not “look beyond the pleadings” in ruling on the motion to dismiss. Hamilton Materials, Inc. v. Dow Chem. Corp., 494 F.3d 1203, 1207 (9th Cir. 2007). 4 25-790
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