Trust Beneficiary Lacks Standing to Sue in Individual Capacity for Trust Property; Forged Trust Instrument Cannot Be Challenged by Improper Plaintiff

Business Law and Estate Planning Controversies

Trust Beneficiary Lacks Standing to Sue in Individual Capacity for Trust Property; Forged Trust Instrument Cannot Be Challenged by Improper Plaintiff

Prepared March 15, 2026

Court: Appellate Court of Maryland

Date: March 13, 2026

Citation: Lucille S. White v. Britney R. Lee, et al., No. unreported, 2026 WL 709616 (Md. App. Mar. 13, 2026)

Summary of Relevant Facts

Lucille S. White purchased property in Upper Marlboro, Maryland in 1999 and created the White Family Revocable Trust in 2004, designating herself as grantor and trustee and conveying the property to herself as Trustee. In 2014, White was convicted of mail fraud, wire fraud, money laundering, and aggravated identity theft and incarcerated in federal prison until 2022.

On December 12, 2019, while White remained incarcerated, her daughter Britney Lee—purporting to act as successor trustee—conveyed the property to Abimbola Shadare for $427,611.00. Lee presented a trust instrument at settlement naming herself as successor trustee, which White alleges was forged. White discovered the sale in 2020 but did not file suit until November 2023, proceeding pro se in her individual capacity rather than as trustee.

Procedural Background

White filed an "Emergency Complaint to Set Aside Deed for Forgery and Intentional Fraud" in Prince George's County Circuit Court, naming multiple defendants including Lee, Shadare, the title company, the settlement attorney, and the mortgage holders. Through a series of motions, all defendants were dismissed. White attempted to cure the standing defect by amending the complaint to add herself as trustee, but the court dismissed the entire case with prejudice. The Appellate Court affirmed on March 13, 2026.

Main Controversies

1. Whether a beneficiary of a revocable trust may sue in individual capacity to recover or quiet title to property held by the trust, when the property title is vested in the trust entity itself.

2. Whether a procedurally defective complaint can be cured by amending to add the trust as plaintiff when no proper plaintiff existed from the outset, under the Washington Homes doctrine.

3. Whether a bona fide purchaser for value who relied on a forged trust instrument at settlement bears any liability to beneficiaries absent specific allegations of fraud or knowledge of the forgery.

4. Whether the statute of limitations barred the claim, given that White knew of the sale by June 2020 but did not file suit until November 2023.

Positions of the Parties

White argued that as grantor, trustee, and beneficiary she possessed sufficient interest to bring suit individually, and attempted to cure the defect by amending to add herself as trustee. She alleged the trust instrument was forged and that all parties who participated in or benefited from the transaction were liable.

Defendants argued that White, suing individually, lacked standing because title was vested in the Trust, not in her personally. Shadare argued she was a bona fide purchaser who properly relied on documents presented at settlement.

Court's Holding

The Appellate Court unanimously affirmed dismissal of all claims. White lacked standing in her individual capacity because property title was vested in the Trust, not in her personally. The amendment adding the Trust as plaintiff was procedurally barred under the Washington Homes doctrine. Shadare was properly dismissed because the complaint stated no legal theory imposing liability on a purchaser absent allegations of fraud or knowledge of the forgery.

Key Reasoning and Analysis

Under Maryland Real Property Article § 14-108(a), only persons in "actual peaceable possession of property" or with an ownership interest may bring a quiet title action. White alleged the property was vested in herself as Trustee—a fiduciary capacity distinct from personal ownership. She never alleged the Trust's interest was conveyed to her individually.

The Washington Homes doctrine precludes amendment to add a proper plaintiff when no proper plaintiff existed from the outset. Rule 2-341(c)(5) requires that "one of the original plaintiffs" remain a party when correcting nonjoinder. Since White was not a proper plaintiff individually, she could not amend her way around the defect.

On Shadare's liability, the bare assertion that she "knew or should have known" of the forgery, without factual predicates, was legally insufficient. A purchaser in an arm's-length transaction may generally rely on documents presented as authoritative at settlement.

Significance and Takeaways

This decision reinforces standing as an absolute threshold requirement in property litigation. The critical distinction between holding property in a fiduciary capacity and holding it individually has significant implications for trust administration: beneficiaries cannot sue individually for trust property but must bring claims in a representative capacity or seek appointment as trustee. The Washington Homes doctrine's strict approach to amendment—prohibiting addition of a proper plaintiff when no proper plaintiff existed originally—imposes significant procedural consequences on litigants who fail to establish proper capacity at the outset. The holding regarding bona fide purchasers reinforces the finality of arms-length real estate transactions and the protection of the recording system.