In some circumstances, a typed name may qualify as a signature on a pleading.
In Jones v. Mortgage Menders, LLC, No. M2017-01452-COA-R3-CV (Tenn. Ct. App. Feb. 21, 2018), plaintiff initially filed his complaint in 2006, then took a voluntary nonsuit on February 12, 2016. Plaintiff, acting pro se, filed a “purported complaint” on February 2, 2017, attempting to re-assert the original claims. This pleading “featured his typewritten name rather than his handwritten signature.”
The court clerk alerted plaintiff to the lack of signature , but instead of signing the complaint, plaintiff “signed a certificate of service.” Defendants moved for summary judgment, which the trial court granted, finding that the lack of signature meant that the complaint did “not satisfy the signature requirement under Rule 11,” and further finding that the purported complaint was so deficient as to not be a complaint at all. The Court of Appeals overturned these holdings.