Aaron Techlin v. American Express Company

OFFICE OF THE CLERK
WISCONSIN COURT OF APPEALS
110 EAST MAIN STREET, SUITE 215
P.O. BOX 1688
MADISON, WISCONSIN 53701-1688
Telephone (608) 266-1880
TTY: (800) 947-3529
Facsimile (608) 267-0640
Web Site: www.wicourts.gov
DISTRICT III
September 29, 2026
To:
Barb Bocik
Clerk of Circuit Court
Outagamie County Courthouse
Electronic Notice
Jacquelyn K. Adamicki
Electronic Notice
Michael W. Curry
Electronic Notice
Aaron Techlin
Electronic Notice
You are hereby notified that the Court has entered the following opinion and order:
2025AP1668 Aaron Techlin v. American Express Company
(L. C. No. 2025CV127)
Before Stark, P.J., Hruz, and Gundrum, JJ.
Summary disposition orders may not be cited in any court of this state as precedent or
authority, except for the limited purposes specified in WIS. STAT. RULE 809.23(3).
Aaron Techlin, as “Beneficiary and Trustee” of the “Techlin Equitable Commerce Trust,”
pro se, appeals an order that dismissed Techlin’s complaint against American Express Company
for failure to state a claim upon which relief could be granted. Based upon our review of the briefs
and record, we conclude at conference that this case is appropriate for summary disposition. See
WIS. STAT. RULE 809.21 (2023-24). We dismiss the appeal for lack of jurisdiction.
Techlin, pro se, filed the instant lawsuit against American Express in January 2025. The
complaint identified the plaintiff in the lawsuit as “Aaron Techlin, Beneficiary of the Techlin
Equitable Commerce Trust,” and described the Trust as “a private trust operating under principles

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of equity.” The complaint further stated that Techlin “brings this action in his private capacity as
the equitable Beneficiary of the trust.”
The complaint alleged that on December 3, 2024, Techlin “submitted a $21.00 United
States Postal Money Order to [American Express] as a Special Deposit under the principles of
equity, accompanied by a ‘Special Deposit Notice and Declaration of Settlement’ outlining the
terms of the deposit.” The complaint further alleged that the “Special Deposit Notice” “expressly
stated that the money order was tendered to facilitate the equitable conversion of its legal face
value ($21.00) to the full equitable value of $27,047.97, representing the complete satisfaction of
the outstanding balance on the referenced account ending in 21008.” According to the complaint,
despite the instructions in the “Special Deposit Notice,” American Express “improperly applied
the money order solely at its legal face value of $21.00.” The complaint further alleged that
American Express “failed to cure the breach,” despite Techlin sending it multiple notices of
default.
Based on these allegations, the complaint asserted that American Express had breached its
fiduciary duty by “[f]ailing to apply the money order as trust property for its full equitable value”;
“[i]gnoring the express instructions outlined in the Special Deposit Notice”; and “[d]isregarding
[Techlin’s] administrative notices and demands for correction.” The complaint also sought a
declaration that “[t]he money order constitutes trust property under the principles of equity” and
that American Express has a “fiduciary obligation to apply the money order for its full equitable
value as outlined in the Special Deposit Notice.” The complaint further sought an injunction
requiring American Express to “[a]cknowledge receipt of the money order as trust property” and
“[a]pply the money order for its full equitable value of $27,047.97 to discharge the referenced

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account balance.” In addition, the complaint asked the circuit court to award both compensatory
and punitive damages.
In April 2025, American Express moved to dismiss Techlin’s complaint for failure to state
a claim upon which relief could be granted. The circuit court orally granted that motion on July 16,
2025, following a nonevidentiary hearing. The court explained that “there just is no factual basis
[in the complaint] that states a legal claim against [American Express] that would support, in any
way, any relief, … including the relief that [Techlin] seeks in this case.” The court subsequently
entered a written order granting the motion to dismiss.
Techlin filed a notice of appeal from the circuit court’s order. He signed the notice of
appeal as, “Aaron Techlin, Beneficiary.” However, the signature block below his signature stated:
Aaron Allan Techlin
Beneficiary and Trustee
Techlin Equitable Commerce Trust
Petitioner, Pro Se
The reference to “Trustee” in the notice of appeal’s signature block led this court to
question the extent of our jurisdiction over this appeal. See Carla B. v. Timothy N., 228 Wis. 2d
695, 698, 598 N.W.2d 924 (Ct. App. 1999) (stating that this court has a “duty to inquire as to
whether we lack jurisdiction to proceed”). As a result, we directed the parties “to address, as the
first issue on appeal, whether we have jurisdiction to consider each of the issues presented in the
briefs.” Having reviewed the parties’ briefs, we now conclude that we lack jurisdiction over this
appeal.
As noted above, the notice of appeal in this case was filed by Techlin, pro se, as
“[b]eneficiary and [t]rustee” of the “Techlin Equitable Commerce Trust.” Techlin asserts that he

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is appealing the circuit court’s decision in his “own name,” not on behalf of the Trust, and that the
Trust “is not acting as a party here.” We agree with American Express, however, that Techlin,
personally, lacks standing to bring the claims asserted in the complaint and to challenge the circuit
court’s dismissal of those claims on appeal.
The central question, for purposes of standing, “is whether ‘a party has a sufficient stake
in an otherwise justiciable controversy to obtain judicial resolution of that controversy.’” Norquist
v. Zeuske, 211 Wis. 2d 241, 247, 564 N.W.2d 748 (1997) (citation omitted). “Wisconsin employs
a two-step standing analysis,” which “requires the court to determine (1) whether the plaintiff has
suffered a threatened or actual injury, and (2) whether the interest asserted is recognized by law.”
Id. at 247-48.
Here, the allegations in the complaint do not show that Techlin, personally, has suffered
any threatened or actual injury as a result of American Express’s alleged conduct. Instead, the
complaint alleges that the Trust suffered an injury when “trust property”—namely, the $21 money
order—was received by American Express and “improperly applied.” As American Express
correctly notes, “The only asset at issue in this appeal belonged to the Trust, not to Techlin. If
there are any claims of misuse or misapplication of those funds, such claims would necessarily
involve injury to the Trust, and not to Techlin in his individual capacity.” We therefore conclude
that Techlin, personally, lacks standing to assert the claims alleged in the complaint and to
challenge the circuit court’s dismissal of those claims on appeal.
Furthermore, Techlin, a nonlawyer, cannot represent the Trust’s interests on appeal. See
Life Sci. Church, Bible Camp & Christian Liberty Acad. v. Shawano County, 221 Wis. 2d 331,
334, 585 N.W.2d 625 (Ct. App. 1998) (holding that a trust must be represented by legal counsel

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and that a nonlawyer trustee may not file a notice of appeal on behalf of a trust). “When a notice
of appeal is not signed by an attorney when an attorney is required, the notice of appeal is
fundamentally defective and cannot confer jurisdiction on this court.” Brown v. MR Grp., LLC,
2004 WI App 122, ¶6, 274 Wis. 2d 804, 683 N.W.2d 481. Consequently, the notice of appeal filed
by Techlin in this case—challenging the circuit court’s dismissal of claims asserted by Techlin on
behalf of the Trust—is fundamentally defective. We therefore dismiss this appeal for lack of
jurisdiction.
Therefore,
IT IS ORDERED that the appeal is summarily dismissed for lack of jurisdiction. WIS.
STAT. RULE 809.21 (2023-24).
IT IS FURTHER ORDERED that this summary disposition order will not be published.
Samuel A. Christensen
Clerk of Court of Appeals