A federal court has dismissed a case brought by Carolyn Bullock against PHH Mortgage Services and Deutsche Bank National Trust Company. The District Court for the District of Columbia ruled that the court lacks jurisdiction over the matter, which involves a trust and ongoing probate proceedings. This decision affects Bullock, who is acting as a trustee, and the defendants, who are involved in the management of the trust's assets.
The case, titled Bullock v. PHH Mortgage Services, was filed on July 14, 2026, under Civil Action No. 2025-3820. Bullock, representing herself in the case, alleged that the defendants breached their fiduciary duties and engaged in deceptive practices regarding the estate of Jerone M. Browner-El. The dispute centers around the authority of the defendants to manage and service the property owned by the trust.
Bullock's claims arose amid ongoing probate proceedings in the Superior Court of the District of Columbia, where PHH and Deutsche Bank are also listed as applicants and creditors. In her complaint, Bullock demanded that the court declare the rights and obligations of the parties involved and sought to prevent the defendants from enforcing any claims against the trust without proper proof of authority.
The court's ruling, delivered by Judge Tanya S. Chutkan, emphasized that Bullock could not represent the trust in federal court without legal counsel. The court cited 28 U.S.C. § 1654, which states that parties may represent themselves personally or through counsel. The court noted that even though Bullock was authorized as a trustee, she could not act on behalf of the trust without an attorney. The ruling stated, "A plaintiff, who is proceeding pro se, cannot represent the trust in federal court, even as the trustee, as he is not a licensed attorney."
Additionally, the court highlighted that federal district courts generally do not have the authority to review decisions made by local courts in the District of Columbia. This principle, known as the "probate exception," prevents federal courts from interfering in ongoing probate matters, which are typically handled by state courts. The court explained, "To grant Plaintiff’s requested relief, the court would need to make determinations that would impact the administration of the trust and its assets."
Judge Chutkan's opinion concluded that Bullock's claims fell within the probate exception, leading to the dismissal of the case. The court stated, "These are the very decisions that should be made, not by a federal court sitting in diversity, but by the local probate court with active jurisdiction over the trust." As a result, the court dismissed the case without prejudice, meaning Bullock may have the option to refile in the appropriate court.
This ruling has significant implications for Bullock and others in similar situations. It reinforces the principle that individuals representing trusts or estates must have legal representation when pursuing claims in federal court. Additionally, the decision underscores the limitations of federal jurisdiction over probate matters, which are typically reserved for state courts.
Moving forward, Bullock may seek to pursue her claims in the appropriate local court, but she will need to obtain legal counsel to do so. The dismissal also serves as a reminder to individuals involved in trust and estate matters to understand the jurisdictional boundaries of federal and state courts.
Details were not available in the court filing regarding whether Bullock plans to appeal the decision or if there are any related cases pending. However, the court noted that Bullock had previously attempted to file a similar lawsuit, which was also dismissed for lack of subject matter jurisdiction.