In United States v. Hagerman & Wabash Environmental Technologies, LLC, 2008 U.S. App. LEXIS 20317 (7th Cir. 9/08), defendants were convicted of criminal violations of the Clean Water Act. The government, contending that Wabash had violated the conditions of probation by refusing to begin paying the restitution (and a $4,000 special assessment) that had been ordered, petitioned the District Court for relief, as authorized by 18 U.S.C. Section 3563(c). The District Court thereafter dismissed the petition after the government and Wabash resolved their differences by Wabash''s agreeing to start paying restitution and to furnish specified information concerning the company''s finances. Nevertheless, Wabash and Hagerman filed an appeal. The Court of Appeals ruled that Hagerman''s appeal must be dismissed because he was not a party to the probation violation proceeding. The appeal by Wabash was dismissed for two reasons. First, the Court held that Wabash''s appeal must be dismissed because it was not aggrieved by the dismissal of the probation violation proceeding. Second, the Court noted that Wabash had no lawyer in the Court of Appeals (it had been represented in the District Court by a lawyer who subsequently withdrew). Hagerman, who is not a lawyer, claimed the right to represent Wabash because he is not only a major stockholder [presumably he meant ''member,'' since Wabash is an LLC, not a corporation] but is also the current President of Wabash. It was Hagerman who filed the appeal on behalf of Wabash and himself. He complained to the Court of Appeals about the deal that Wabash struck with the government in the probation proceeding. The Court noted that in Federal court a corporation is not permitted to litigate unless it is represented by a lawyer licensed to practice before that court; there are exceptions for individuals involved in civil cases [e.g., cannot afford counsel, very unpopular cause], but no exceptions for corporations. Although whether an LLC must be represented by counsel was almost a case of first impression [only one case was found, and it was not directly on point], the Court concluded that the same rule would apply to an LLC. As such, the appeal by the LLC was dismissed (2nd reason) because the entity was not represented by counsel. The Court also noted in dictum that the representation requirement would apply to any business entity (e.g., partnership) since, like a corporation, they were merely forms of doing business.