Non-Attorney Representation
NON-ATTORNEY REPRESENTATION IN ADMINISTRATIVE LAW PROCEEDINGS
As a Certified Paralegal and Legal Document Preparer (Legal Document Assistant – California), Mr. Nwosu is trained in a variety of core legal specialties, including contracts, torts, property, and criminal law. This level of expertise uniquely qualifies him to assist in the areas of legal research, legal writing, and litigation support services to individuals, businesses, attorneys, and government agencies throughout the United States and abroad, where permitted under state, federal, and international law. Mr. Nwosu is not an attorney and therefore cannot give legal advice nor represent individuals or entities in court.
Mr. Nwosu and SUN INC are authorized to enter non-attorney appearances (to advise and make administrative court appearances in administrative law proceedings) on the behalf of self-represented individuals and entities before administrative agencies involving legal matters such as Procurement Bid Protests, Unemployment Appeals, ACA Marketplace Appeals, SSA Appeals, and EEOC Complaints, amongst other administrative agency matters, throughout the United States were permitted under state and federal law.
Federal & State Administrative Agency Proceedings.
Seth Usifo Nwosu Incorporated (SUN INC) provides non-attorney representation and administrative advocacy support in federal and state administrative proceedings where such representation is expressly permitted by statute, regulation, or agency rule.
Administrative law is distinct from court-based litigation. In many administrative forums, individuals, businesses, and organizations may appear on their own behalf, through licensed counsel, or through a designated non-attorney representative, subject to the procedural requirements of the governing agency. SUN INC operates exclusively within those authorized administrative frameworks.
FEDERAL AGENCIES THAT RECOGNIZE NON-ATTORNEY REPRESENTATION
Federal administrative law permits non-attorney representation in a variety of agency proceedings, subject to agency-specific statutes, regulations, and procedural rules. Federal agencies and administrative forums that expressly recognize non-attorney representatives in defined administrative contexts include, among others:
- Social Security Administration (SSA) - Administrative adjudications involving benefits determinations and appeals.
- Department of Veterans Affairs (VA) - Benefits-related administrative proceedings governed by VA regulations.
- Internal Revenue Service (IRS) - Administrative practice before the agency in tax-related matters, subject to Treasury and agency rules.
- U.S. Patent and Trademark Office (USPTO) - Specific administrative matters governed by USPTO practice regulations.
- National Labor Relations Board (NLRB) - Administrative hearings and proceedings involving labor-management relations.
- Department of Labor (DOL) - Administrative adjudications conducted through agency components and the Office of Administrative Law Judges.
- Merit Systems Protection Board (MSPB) - Administrative appeals involving federal employment and personnel actions.
- Government Accountability Office (GAO) - Administrative procurement bid protest proceedings, including challenges to federal contract awards and procurement actions.
- Centers for Medicare & Medicaid Services (CMS) / HealthCare.gov Marketplace eligibility and enrollment appeals, where individuals may appoint an authorized representative to act on their behalf during the administrative appeals process.
- Equal Employment Opportunity Commission (EEOC) - Administrative EEO charge proceedings, including the filing and processing of discrimination complaints under federal equal employment opportunity regulations.
SCOPE OF SERVICES (WHERE AUTHORIZED)
In authorized administrative forums, SUN INC may assist clients with:
- Administrative appeals and reviews
- Regulatory and compliance-related proceedings
- Benefits and eligibility determinations
- Licensing, certification, and enforcement matters
- Procurement and bid-related administrative issues
- Employment-related administrative complaints and appeals
- Policy-driven or quasi-judicial administrative adjudications
Services are tailored to the procedural posture of the matter and the rules of the governing agency.
Comparison Table: Federal vs. State Administrative Proceedings
Feature | Federal Administrative Proceedings | State Administrative Proceedings |
Governing Framework | Federal Administrative Procedure Act (APA) + agency-specific rules | State Administrative Procedure Acts + agency rules |
Decision-Maker | Federal ALJ, hearing officer, or agency adjudicator | State ALJ, hearing officer, or agency adjudicator |
Representation Options | Self-representation, attorney, or non-attorney representative (where permitted) | Self-representation, attorney, or non-attorney representative (where permitted) |
Scope of Authority | Defined by federal statutes and regulations | Defined by state statutes and regulations |
Procedural Emphasis | Record-based review, regulatory compliance, administrative hearings | Record-based review, regulatory compliance, administrative hearings |
Court Involvement | Limited; judicial review typically occurs after final agency action | Limited; judicial review typically occurs after final agency action |
SUN INC Role | Non-attorney administrative representation and support where authorized | Non-attorney administrative representation and support where authorized |
GENERAL FEDERAL ADMINISTRATIVE PRACTICE.
At the federal level, administrative proceedings are governed by the Administrative Procedure Act (APA) and by agency-specific practice rules. Unlike Article III courts, federal administrative agencies often permit parties to designate representatives who are not licensed attorneys, particularly in adjudicatory, benefits-related, regulatory, procurement, employment, and compliance-focused matters.
Across federal administrative forums, non-attorney representatives may be authorized to:
- Appear on behalf of a party in administrative proceedings
- Prepare and submit filings, petitions, appeals, and written statements
- Organize and present documentary evidence and exhibits
- Communicate with agency personnel, adjudicators, and administrative bodies
- Participate in hearings, conferences, and administrative reviews
- Assist with procedural compliance, record development, and case management
The permissibility, scope, and conditions of non-attorney representation are determined by the specific agency and by the type of proceeding involved. SUN INC evaluates each matter individually to confirm that non-attorney representation is authorized under the applicable federal framework.
STATE ADMINISTRATIVE AGENCY PROCEEDINGS
In addition to federal matters, many states permit non-attorney representation in administrative agency proceedings under their respective Administrative Procedure Acts (APAs) or agency-specific rules.
SUN INC provides non-attorney administrative representation and support on a case-by-case basis, evaluating:
- The state agency involved
- The nature of the administrative proceeding
- The governing statutes and regulations
- Any procedural or eligibility requirements applicable to non-attorney representatives
This approach ensures compliance with state-level regulatory frameworks while preserving access to professional administrative advocacy.
WHY ADMINISTRATIVE REPRESENTATION IS DIFFERENT FROM COURT REPRESENTATION
Administrative proceedings are not court cases. They are governed by statutes, regulations, and agency rules designed to resolve disputes within an executive or regulatory framework. As a result:
- Administrative forums often allow parties to appear without an attorney or with a non-attorney representative, subject to agency rules.
- Procedures emphasize regulatory compliance, record development, and agency expertise, rather than formal trial practice.
- Decision-makers are typically administrative law judges, hearing officers, or agency adjudicators, not juries.
- Judicial review, if available, generally occurs after final agency action.
SUN INC’s practice is limited to authorized administrative forums and does not include court appearances or the practice of law.
PROFESSIONAL & ETHICAL BOUNDARIES
SUN INC is a non-attorney legal services and consulting firm. Accordingly:
- We do not provide legal advice or legal opinions
- We do not represent clients in federal or state courts
- We do not hold ourselves out as a law firm
- We operate solely within administrative forums that permit non-attorney representation
When a matter requires licensed legal counsel, SUN INC advises clients to consult an attorney admitted to practice in the appropriate jurisdiction.
OUR APPROACH
SUN INC’s non-attorney representation practice emphasizes:
- Regulatory compliance
- Procedural accuracy
- Administrative efficiency
- Ethical clarity
- Client empowerment within authorized forums
This disciplined approach allows clients to navigate complex administrative systems with professional support while respecting the boundaries between administrative advocacy and the practice of law.
REFERENCES (SELECTED, NON-EXHAUSTIVE)
- Administrative Procedure Act, 5 U.S.C. §§ 551–559
- Agency Practice Act, 5 U.S.C. § 500
- 20 C.F.R. Parts 404 & 416 (SSA)
- 38 C.F.R. Part 14 (VA)
- 31 C.F.R. Subtitle A, Part 10 (IRS – Circular 230)
- 37 C.F.R. Parts 11 & 41 (USPTO)
- 29 C.F.R. Part 102 (NLRB)
- 29 C.F.R. Part 18 (DOL OALJ)
- 5 C.F.R. Part 1201 (MSPB)
- GAO Bid Protest Regulations, 4 C.F.R. Part 21
- 29 C.F.R. Part 1614 (EEOC Federal Sector EEO)
Appointment Only
Our Locations
Corporate HQ
5757 Wayne Newton Boulevard, Ste. 11292 Las Vegas, NV 89111
Arizona
2550 E Rose Garden Lane, Ste. 71914 Phoenix, AZ 85050
New Jersey
2 Federal Square, Ste. 28284 Newark, NJ 07101
California
8821 Aviation Boulevard, Ste. 90551 Los Angeles, CA 90009
Florida
2200 NW 72nd Avenue, Ste. 524601 Miami, FL 33152
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SUN INC is a non-attorney legal services firm and does not provide legal advice or attorney representation. A retainer is required to retain our professional services.