The question involved here is the right of a "person," not an attorney, to bring action or defend in a court of law. If a natural person may represent himself, why cannot a corporation choose to represent itself in court without the aid of an attorney? The question is posed with the thought in mind that in the eyes of the law a corporation is a legal entity and, therefore, should be permitted to appear in state and federal courts solely through the representation of an agent. This kind of a court appearance, whether by a natural person or by a corporation, is referred to as an appearance in propria persona.
Timothy G. Cotner, May a Corporation Act as Its Own Attorney, 16 Clev.-Marshall L. Rev. 173 (1967)