United States Court of Appeals 

For the Seventh Circuit 

Chicago, Illinois 60604 

Submitted June 2, 2021*

Decided June 2, 2021 

Before 

DAVID F. HAMILTON, Circuit Judge 

MICHAEL B. BRENNAN, Circuit Judge 

THOMAS L. KIRSCH II, Circuit Judge

No. 21-1123 

MICHELLE L. DRIDI and DENNIS L. 

FULNER, 

Plaintiffs-Appellants, 

v. 

AMERICAN FAMILY MUTUAL 

INSURANCE COMPANY, S.I., 

Defendant-Appellee.

 Appeal from the United States District 

Court for the Southern District of Indiana, 

Indianapolis Division. 

No. 1:20-cv-01770-TWP-MPB 

Tanya Walton Pratt, 

Chief Judge. 

O R D E R 

 Michelle Dridi brought suit on behalf her father against American Family Mutual 

Insurance Company in Indiana state court. After American Family removed the suit to 

federal court, a magistrate judge cited a prohibition on non-lawyers litigating on behalf 

of another and directed the father to comply. The court dismissed the case without 

*

 We have agreed to decide the case without oral argument because the briefs and 

record adequately present the facts and legal arguments, and oral argument would not 

significantly aid the court. FED. R. APP. P. 34(a)(2)(C). 

NONPRECEDENTIAL DISPOSITION 

To be cited only in accordance with 

Fed. R. App. P. 32.1 
No. 21-1123 Page 2 

prejudice when Dridi continued to represent her father. Because Dridi and her father 

ignored warnings that, as a non-attorney, Dridi could not represent her father (and she 

does not seek to pursue a personal claim), we affirm. 

The complaint, signed by Dridi as “power of attorney” for her father, alleges that 

American Family breached its obligation to pay Dridi’s father on his insurance claim 

after a fire destroyed his house. She is not a licensed attorney, and she does not assert a 

personal claim against American Family. A magistrate judge explained that a “power of 

attorney” does not confer the ability to practice law. He allowed her one month to find 

an attorney for the father; if she persisted in representing him, the judge warned that he 

would recommend dismissal. 

 Dridi and her father did not comply. During the next month, Dridi’s father 

moved the court to recruit counsel. But he submitted no evidence of his financial status, 

so the magistrate judge denied the motion and reminded him of the need either to 

represent himself or find an attorney. Shortly before the one-month deadline, the father 

attested that he “want[ed]” to proceed pro se, but he needed his daughter to manage 

the case because, among other deficits, “[his] mind doesn’t remember things like it used 

to.” Interpreting this assertion as reflecting that Dridi would still control the father’s 

litigation, the magistrate recommended dismissal. Dridi objected, arguing that, having 

“power of attorney” for her father, she had a right to argue her father’s claims pro se. 

The district court overruled Dridi’s objections, concluding that a power of attorney does 

not confer the ability to represent the principal. It then dismissed the complaint without 

prejudice under Federal Rule of Civil Procedure 41(b) for failing to comply with the 

order to secure an attorney. It also advised Dridi’s father that he could refile himself or 

with the assistance of licensed counsel. So far as we know, he has done neither. 

 The appellate brief (which Dridi’s father appears to authorize and which we may 

therefore consider) focuses principally on the merits of the contract claim. It contains 

only conclusory, undeveloped arguments about the ability of Dridi, unlicensed to 

practice law, to represent her father in the district court. Because of the absence of a 

response to the district court’s rationale for dismissal, we could affirm on this basis 

alone. Williams v. Bd. of Educ., 982 F.3d 495, 511 (7th Cir. 2020). But we explain why the 

district court permissibly dismissed the complaint under Rule 41(b). 

As her father’s attorney-in-fact but not a licensed attorney, Dridi could not 

represent him during the proceedings in the district court. We discussed this rule in 

Elustra v. Mineo, 595 F.3d 699, 702 (7th Cir. 2010). In that case a mother filed a falseimprisonment suit on behalf of her children. Although she could file the suit, we 
No. 21-1123 Page 3 

enforced a federal rule that prohibited her from arguing on behalf of the children in 

federal court during the suit. Id. at 704. She needed to retain counsel because, like Dridi, 

she was not a lawyer and the claims were not her own. Id. at 704–05. Barring Dridi from 

representing her father “jealously guards the judiciary’s authority to govern those who 

practice in its courtrooms.” Id. at 705 (quoting Myers v. Loudoun Cnty. Pub. Schs., 

418 F.3d 395, 400 (4th Cir. 2005)). Like the rule in Elustra, the Southern District of 

Indiana’s rules permit “only members of the court’s bar” to practice before it with an 

exception for pro se litigants representing themselves. S.D. Ind. Loc. R. 83-5(a)(1)–(2)(A). 

Litigants could circumvent this rule if they could confer the ability to practice law to 

anybody by the facile expedient of signing a power of attorney. Therefore, the district 

court reasonably decided that Dridi, acting as attorney-in-fact, cannot argue her father’s 

claims pro se on his behalf. 

The district court’s decision to dismiss the suit without prejudice in order to 

enforce the non-compliance with this rule was also reasonable. Courts have the inherent 

authority to dismiss actions for a litigant’s failure to obey reasonable court orders. Link 

v. Wabash R.R. Co., 370 U.S. 626, 630–32 (1962); O’Rourke Bros. Inc. v. Nesbitt Burns, Inc., 

201 F.3d 948, 952 (7th Cir. 2000). Before exercising this power, we have instructed 

district courts to warn litigants of the consequences of their disobedience. Shaffer v. 

Lashbrook, 962 F.3d 313, 316 (7th Cir. 2020). The district court here did so. It informed the 

father and Dridi of the rule, warned them that dismissal was possible if the father did 

not comply with the rule, and reminded them of the rule as the deadline for compliance 

neared. When the father did not comply after the deadline, the district court permissibly 

enforced the rule by dismissing his suit without prejudice and inviting him to refile. 

We recognize that, in the father’s affidavit, he said that he “want[s]” to proceed 

pro se, but the district court reasonably ruled that this aspiration was insufficient. First, 

the father acknowledged in the same affidavit that he was incapable of managing the 

litigation himself and needed his daughter to do so. Therefore, the court reasonably 

concluded that the father would not be able to fulfill his aspiration. Second, in Dridi’s 

objections to the recommendation to dismiss, she argued only that she had the right to 

argue her father’s case, not that he would control the litigation. With her disobedience 

of the court’s order therefore evident, and with no indication of the father’s willingness 

to comply with its order, the court’s decision to dismiss the case without prejudice was 

sound. See Salata v. Weyerhaeuser Co., 757 F.3d 695, 699 (7th Cir. 2014). 

AFFIRMED