Geraldine Henson, as Personal Representative of the Estate of David Henson v. Kelley Cradduck

Summary

The court affirmed dismissal of the estate's wrongful-death complaint as untimely. It held that the personal representative's original pro se complaint constituted the unauthorized practice of law and was therefore a nullity, so later attorney-filed complaints could not relate back to it and were filed after the three-year limitations period. The court also held that the law-of-the-case doctrine did not bar review because the prior appeal had resolved only appellate jurisdiction.