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A.R.S. § 14-1105

Court Remedies for Unreasonable Conduct in Arizona Estate and Trust Proceedings

Verified April 4, 2026 • 57th Legislature, 1st Regular Session

When someone's unreasonable behavior causes an estate, trust, ward, or protected person to incur unnecessary professional fees, Arizona courts can order the responsible party to pay those costs. This statute gives courts the power to shift fees onto bad actors and their attorneys.

Title 14, GENERAL PROVISIONS, DEFINITIONS AND PROBATE JURISDICTION OF COURTS

azleg.gov

When Bad Behavior Creates Unnecessary Costs

Estate and trust disputes can escalate quickly. Sometimes a party or their attorney engages in conduct that runs up fees without any legitimate purpose. A.R.S. 14-1105 gives courts a direct remedy: if unreasonable conduct causes professional fees or expenses, the court can order the person responsible to reimburse the estate, trust, ward, or protected person.

If the court finds that a decedent's estate or trust has incurred professional fees or expenses as a result of unreasonable conduct, the court may order the person who engaged in the conduct or the person's attorney, or both, to pay the decedent's estate or trust for some or all of the fees and expenses as the court deems just under the circumstances.

A.R.S. § 14-1105(A)

Notice that both the individual and their attorney can be held responsible. This is unusual. Most fee-shifting statutes target only one or the other. Here, the court has discretion to impose the obligation on either or both.

Protection Extends to Guardianship and Conservatorship Cases

The statute is not limited to estate and trust matters. Subsection B applies the same rule to guardianship and conservatorship cases. If unreasonable conduct forces a ward or protected person to spend money on professional fees, the court can shift those costs to the responsible party.

These remedies are cumulative. They do not replace other civil remedies or legal provisions. They add another layer of protection, specifically designed to prevent bad-faith conduct from draining the assets that a ward, protected person, or estate beneficiary depends on. The statute defines key terms broadly, covering accountants, attorneys, fiduciaries, physicians, psychologists, registered nurses, guardians ad litem, and expert witnesses.

A. If the court finds that a decedent's estate or trust has incurred professional fees or expenses as a result of unreasonable conduct, the court may order the person who engaged in the conduct or the person's attorney, or both, to pay the decedent's estate or trust for some or all of the fees and expenses as the court deems just under the circumstances. B. In a guardianship or conservatorship case, if the court finds that a ward or protected person has incurred professional fees or expenses as a result of unreasonable conduct, the court may order the person who engaged in the conduct or the person's attorney, or both, to pay the ward or protected person for some or all of the fees and expenses as the court deems just under the circumstances. C. The remedies allowed pursuant to this section are in addition to any other civil remedy or any other provision of law. The remedies allowed pursuant to this section may be invoked to mitigate the financial burden on a ward, protected person, decedent's estate or trust incurred as a result of unjustified court proceedings or unreasonable or excessive demands made on a fiduciary, fiduciary's attorney, court-appointed attorney, guardian ad litem or representative. D. For the purposes of this section: 1. "Court-appointed attorney" means an attorney appointed pursuant to section 14-5303, subsection C, section 14-5310, subsection C, section 14-5401.01, subsection C or section 14-5407, subsection B. 2. "Fiduciary" means an agent under a durable power of attorney, an agent under a health care power of attorney, a guardian, a conservator, a personal representative, a trustee or a guardian ad litem. 3. "Person who engaged in the conduct" includes a fiduciary, an attorney or a guardian ad litem. 4. "Professional" means an accountant, an attorney, a fiduciary, a physician, a psychologist, a registered nurse, a guardian ad litem or an expert witness. 5. "Professional fees or expenses" includes the fiduciary's fees and expenses and the fiduciary's attorney fees and expenses, as well as the fees and expenses of any other professionals hired by the fiduciary or the fiduciary's attorney.
View on azleg.gov

This page provides general legal information about Arizona statutes and is not legal advice. For guidance on how this law applies to your situation, speak with a qualified attorney.

Related Questions

How do guardianship and conservatorship proceedings work in Arizona?

Both require filing with the Arizona Superior Court, medical evidence of incapacity, and a judge's approval. The process takes months and costs thousands. Powers of attorney accomplish the same goals without court involvement.

How do probate attorney fees and retainers work in Arizona?

Probate attorneys in Arizona require a retainer of $1,000 to $5,000 or more upfront. The family pays out of pocket because estate assets are frozen until the court grants authority. Total probate costs typically run $10,000 to $15,000.

How much does probate cost in Arizona?

Probate in Arizona typically costs $10,000 to $15,000 for a standard estate, covering court fees, attorney fees, personal representative fees, appraisals, and accounting. Contested estates cost significantly more.

Related Statutes

§ 14-1101Required Training for Arizona Judges Handling Estate and Trust Cases
§ 14-1102Purposes and Rules of Construction for Arizona Probate and Trust Law
§ 14-1103Supplementary Principles of Law in Arizona Probate Proceedings
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