Alaska Statutes

Alaska Stat. § 22.20.040 (2026)

Appearance

✓ current as of July 2026

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Sec. 22.20.040. Appearance.
(a) An action or proceeding may be prosecuted or defended by a party in person or by attorney. However,
(1) the United States shall appear by an attorney in all cases; and

(2) a corporation, either public or private, shall appear by an attorney in all cases unless an exception to the corporation's appearance by an attorney has been explicitly made by law.

(b) When a party appears by attorney, the written proceedings shall be in the name of the attorney, who is the sole representative of the client as between the client and the adverse party.

Notes of Decisions

Cited in 14 cases (1 in the last 5 years), 1990–2022 · leading case: Roberts v. State, Dep't of Revenue, 162 P.3d 1214 (Alaska 2007).

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Roberts v. State, Dep't of Revenue, 162 P.3d 1214 (Alaska 2007). · cites it 8× “AS 22.20.040 provides in relevant part: (a) An action or proceeding may be prosecuted or defended by a party in person or by attorney.”

Boiko v. Kapolchok, 426 P.3d 868 (Alaska 2018). · cites it 4× “But Kapolchok contorts the purpose of AS 22.20.040, requiring corporations to appear by licensed attorney.”

Daggett v. Feeney, 397 P.3d 297 (Alaska 2017). · cites it 2× “dismissed as appellants [until] an attorney filed an entry of appearance on behalf of all appellants.” 55 The Daggetts represent themselves in this appeal and therefore cannot represent Standard Steel or, for that matter, AWI.”

Casciola v. F.S. Air Serv., Inc., 120 P.3d 1059 (Alaska 2005). “Air's Motion to Strike Jetbroker's Answer and Counterclaim because Jetbroker had not obtained corporate counsel as required by AS 22.20.040. Superior Court Judge Eric Sanders ordered Jetbroker to obtain corporate counsel by August 7, 2002.”

Pister v. State, Dep't of Revenue, 354 P.3d 357 (Alaska 2015). “See AS 22.20.040(a)(2). Northwest Medical and Skyrad were thus briefly dismissed as appellants.”

Parlier v. CAN-ADA Crushing & Gravel Co., 441 P.3d 422 (Alaska 2019). “Parlier's petition is primarily based on distinguishing AS 22.20.040(a)(2), which provides: "a corporation, either public or private, shall appear by an attorney in all cases unless an exception to the corporation's appearance by an attorney has been explicitly made by law.”

Murat v. F/v Shelikof Strait, 793 P.2d 69 (Alaska 1990). “040, which provides that a corporate party “shall appear by an attorney in all cases,” and to Alaska Civil Rule 5(b), which requires that service be made only upon a party’s attorney in cases where a party is represented by an attorney, Murat contends that nothing short of…”

Lane v. Ballot, 330 P.3d 338 (Alaska 2014). “See AS 22.20.040(b) ("When a party appears by attorney, the written proceedings shall be in the name of the attorney, who is the sole representative of the client as between the client and the adverse party.”

Disciplinary Matter Involving Burrell, 882 P.2d 1257 (Alaska 1994). · cites it 2× “18) AS 22.20.040 prohibits a corporation from appearing without an attorney in a civil proceeding (other than a small claim, as was previously mentioned).”

Daggett v. Feeney (Alaska 2017). · cites it 2× “. . dismissed as appellants [until] an attorney filed an entry of appearance on behalf of all appellants.”

William Parlier, McHenry Detective Agency, LLC, & Parlier Inv., LLC v. CAN-ADA Crushing & Gravel Co., D/B/A Crooked Creek Guide Serv., Cabins & RV Park (Alaska 2022). · cites it 2× “We affirmed the superior court and held that AS 22.20.040 required “[a] limited 1 We refer to Rachel by her first name to differentiate her from her father, William Parlier, whom we refer to as Parlier.”

A.L. Cozzetti v. Ray Madrid & All Occupants (Alaska 2017). · cites it 2× “Finally, in his initial FED complaint, Cozzetti represented that Madrid had only a renter’s interest in the mobile home, which the court held violated AS 45.”

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— Alaska Stat. § 22.20.040(a)(2) — 9 cases

Roberts v. State, Dep't of Revenue, 162 P.3d 1214 (Alaska 2007). “AS 22.20.040 provides in relevant part: (a) An action or proceeding may be prosecuted or defended by a party in person or by attorney.”

Boiko v. Kapolchok, 426 P.3d 868 (Alaska 2018). “But Kapolchok contorts the purpose of AS 22.20.040, requiring corporations to appear by licensed attorney.”

Pister v. State, Dep't of Revenue, 354 P.3d 357 (Alaska 2015). “See AS 22.20.040(a)(2). Northwest Medical and Skyrad were thus briefly dismissed as appellants.”

Daggett v. Feeney, 397 P.3d 297 (Alaska 2017). “dismissed as appellants [until] an attorney filed an entry of appearance on behalf of all appellants.” 55 The Daggetts represent themselves in this appeal and therefore cannot represent Standard Steel or, for that matter, AWI.”

— Alaska Stat. § 22.20.040(a2)(2) — 1 case

— Alaska Stat. § 22.20.040(b) — 1 case

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