Coldstream Ministries, A Private Ecclesiastical Trust, By and Through Its Trustees, Daman-Thomas: Caldwell and Jennifer-Leigh: Caldwell, Appearing in Propria Persona, Sui Juris v. Regions Bank, N.A., A National Banking Association

Summary

The United States District Court for the Middle District of Florida struck the complaint filed by trustees appearing without counsel on behalf of a private ecclesiastical trust. The court held that nonlawyer trustees may not represent the trust in federal court, required the trust to obtain counsel and file an amended pleading by January 5, 2026, and denied pending motions as moot.

Holdings

1. A nonlawyer trustee may sue on behalf of a trust as the real party in interest under Federal Rule of Civil Procedure 17, but Rule 17 does not authorize the trustee to serve as legal counsel or otherwise represent the trust in court.
2. A complaint filed by nonlawyer trustees in the name of the trust is a legal nullity and must be disregarded; the complaint was therefore struck.
3. The defendant's motion to dismiss and the plaintiff's motion for summary judgment were denied as moot pending the appearance of counsel for the trust.

Questions Presented

1. Whether nonlawyer trustees may represent a trust in federal court without licensed counsel.
2. Whether a complaint filed on behalf of a trust by nonlawyer trustees must be treated as a legal nullity and disregarded.
3. What relief should be granted concerning the pending motions to dismiss and for summary judgment after the complaint is struck.

Disposition

other