A Florida appeals court has upheld the removal of Kerrin Friedman from her roles as personal representative of her mother's estate and as trustee of three trusts. The decision, made by the Third District Court of Appeal on November 12, 2026, affects Friedman and her family members involved in the estate and trust proceedings. This case highlights the importance of legal representation in probate matters.

The case, identified by docket number 3D2025-2167, involved multiple appeals filed by Friedman challenging orders from the Miami-Dade County Circuit Court. The court's decision underscores the necessity for personal representatives and trustees to comply with legal requirements, particularly regarding the need for legal counsel.

Background

Kerrin Friedman, the appellant in this case, was the personal representative of her mother Bonny L. Wax's estate and also served as the trustee for three related trusts: the Bobbi Ring Trust, the Adam Wax Trust, and the Credit Shelter Trust. The appellees in the case included various parties related to the estate and trusts, including family members who sought Friedman's removal.

The disputes leading to the appeals began when the probate court issued an order requiring Friedman to obtain legal representation. Despite this directive, Friedman chose to represent herself in court, which is against Florida law that mandates personal representatives to have legal counsel unless they are the sole interested party. The probate court subsequently issued orders to remove her from her positions due to her non-compliance with legal requirements.

The Ruling

The Third District Court of Appeal affirmed the lower court's removal orders, stating that the probate court acted within its authority. Chief Judge Scales, along with Judges Lobree and Gooden, noted that the removal was justified due to Friedman’s unauthorized self-representation. The court emphasized that “the probate court did not abuse its discretion in removing Appellant as both personal representative and trustee.”

The court further explained that Florida Probate Rule 5.030(a) requires personal representatives to be represented by an attorney, and the probate court has the authority to remove a personal representative who violates this rule. The court stated, “the probate court has statutory authority to remove a personal representative for violating a court order.” This ruling reinforces the legal framework governing probate and trust administration in Florida.

Impact

This ruling has significant implications for individuals serving as personal representatives or trustees in Florida. It reinforces the necessity for legal counsel in probate matters and clarifies that failure to comply with court orders can lead to removal from these positions. The decision serves as a reminder that individuals must adhere to legal requirements to effectively manage estates and trusts.

The court's affirmation of the removal orders also highlights the importance of due process in probate proceedings. The court found that Friedman had received proper notice and an opportunity to be heard at the September 16, 2025 hearing, countering her claims of due process violations. This aspect of the ruling may influence future cases involving similar disputes over procedural rights in probate matters.

What's Next

Friedman has the option to appeal this decision to the Florida Supreme Court, although it is unclear whether she will pursue this route. There are no related cases pending at this time. The outcome of this case may set a precedent for future probate cases concerning the representation of personal representatives and trustees in Florida.