Muldrow v. Kenilworth Equities, LTD, 1:25-cv-00120

Melvin S. Muldrow Sr. and Marlene C. Williams, self-represented, filed a complaint concerning alleged injury—seemingly involving only Williams—against Kenilworth Equities regarding the Drumcastle apartment complex.
Muldrow filed as a plaintiff but did not clearly allege facts showing that he personally suffered injury from the defendant's conduct.
The Court ordered plaintiffs to amend their complaint to clarify which party had standing and the nature of the claims.
Plaintiffs responded, stating Muldrow's interest as a community member and common-law spouse of Williams but still did not allege a specific, personal injury to Muldrow.
The Court concluded Muldrow lacked standing because he did not suffer a particularized, concrete injury, and his status as Williams’s spouse did not entitle him to represent her or himself.
The complaint was dismissed without prejudice under 28 U.S.C. § 1915 for failure to state a claim; all pending motions were denied as moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing of Muldrow	Muldrow has interest as community member/spouse	No injury to Muldrow alleged	Muldrow lacks standing—no personal injury shown
Pro se representation	Common-law spouse can represent Williams or himself	Pro se cannot represent another	Pro se litigants can only represent themselves
Sufficiency of amended claims	Joint interest sufficient for standing	Must allege concrete injury	Amendments did not cure standing defects
Dismissal with prejudice	Pro se status should garner leniency	Rule violation warrants dismissal	Dismissed without prejudice, allowing future filing

Myers v. Loudoun Cnty. Pub. Sch., 418 F.3d 395 (4th Cir. 2005) (Individuals may not litigate claims on behalf of others pro se)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (Standing requires a concrete and particularized injury in fact)