Nathan D. Ricklin and Megan R. Woolwine v. Nathan D. Clark, Esq., in his fiduciary capacity as Successor Trustee of the Crider Family Share Trust, and Juliette H. Crider

Summary

The United States District Court for the Southern District of Mississippi dismissed plaintiffs’ declaratory-judgment claims concerning whether distributions to the Crider Family Share Trust constituted trust principal or income. The court held that plaintiffs had not adequately alleged diversity of citizenship, concluded alternatively that the probate exception barred the claims because the relevant trust assets remained under the custody and control of the state chancery court, and indicated that abstention would also be appropriate.

Holdings

1. Plaintiffs failed to establish subject-matter jurisdiction under 28 U.S.C. § 1332 because the complaint alleged only the parties' residences and did not allege their citizenship.
2. The probate exception barred Plaintiffs' first declaratory claim because the Trust assets and related distributions were in the custody and control of the Mississippi Chancery Court, and resolving the claim would require the federal court to exercise in rem jurisdiction over those assets.
3. The probate exception barred the second claim because Plaintiffs' request to place the September 5, 2025 distribution in the federal court registry would require the federal court to exercise in rem jurisdiction over property under the state court's control.
4. Even if the court had subject-matter jurisdiction and the probate exception and Anti-Injunction Act did not independently bar the claims, dismissal under the Brillhart abstention doctrine was appropriate.

Questions Presented

1. Whether Plaintiffs adequately alleged complete diversity of citizenship under 28 U.S.C. § 1332.
2. Whether the probate exception to diversity jurisdiction barred Plaintiffs' declaratory claims concerning the classification and distribution of Trust assets subject to the control of the Mississippi Chancery Court.
3. Whether the requested relief would require the federal court to exercise in rem or quasi in rem jurisdiction over property in the custody of the state probate court.
4. Whether the Anti-Injunction Act potentially barred the requested relief because holding the distribution in the federal court registry could interfere with a state-court distribution order.
5. Whether the district court should abstain from exercising jurisdiction over the declaratory-judgment action under Brillhart.

Disposition

dismissed