Arizona Revised Statutes
Ariz. Rev. Stat. § 14-3720 (2026)
Expenses in estate litigation
✓ current as of May 2026
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If any personal representative or person nominated as personal representative defends or prosecutes any proceeding in good faith, whether successful or not he is entitled to receive from the estate his necessary expenses and disbursements including reasonable attorneys' fees incurred.
Notes of Decisions
Cited in 25
cases (1 in the last 5 years), 1978–2024 · leading case: Pierce v. Molet, 87 P.3d 89 (Ariz. Ct. App. 2004).
Pierce v. Molet, 87 P.3d 89 (Ariz. Ct. App. 2004). “§ 14-661, now A.R.S. § 14-3720). Appellees therefore cannot validly claim that they end up paying for appellant’s attorneys’ fees, nor can they successfully assert that payment of such fees is contrary to the intention of the decedent.”
In Re Est. of Friedman, 177 P.3d 290 (Ariz. Ct. App. 2008). “§ 14-3715 authorizes the personal representative to engage in certain transactions on behalf of the estate, and that A.R.S. § 14-3720 (2005) 5 entitles the personal rep *554 resentative to obtain compensation from the estate, but does not preclude payment from other sources.”
Matter of Est. of Killen, 937 P.2d 1375 (Ariz. Ct. App. 1996). “") section 14-3720, for the estate to pay the attorneys' fees and costs incurred by him as personal representative in the will contest.”
Schweiger v. China Doll Restaurant, Inc., 673 P.2d 927 (Ariz. Ct. App. 1983). “2d 989 (1939), the court held that in connection with the predecessor statute to A.R.S. § 14-3720 (providing for reasonable attorneys’ fees in certain probate proceedings) the “payment of an attorney’s fee must be reasonable and bear a direct relation to the amount involved, and…”
Matter of Est. of Brown, 670 P.2d 414 (Ariz. Ct. App. 1983). “, (1939) (the predecessor of A.R.S. § 14-3720 [1] ) which read: Allowed expenses of administration Attorney's Fees .”
Est. of Estes v. Valley Nat'l Bank, 654 P.2d 4 (Ariz. Ct. App. 1982). “Estes contends that the trial court erred in refusing to award pre-judgment interest on the amounts surcharged. She also requests that pre-judgment interest be awarded on all additional items of surcharge as determined by this court.”
In Re Guardianship of Sleeth, 244 P.3d 1169 (Ariz. Ct. App. 2010). “We have interpreted a similar statute, A.R.S. § 14-3720 (2005), which permits reimbursement of a personal representative for attorney’s fees incurred in prosecuting or defending a claim even if the efforts are not successful, as long as the litigation was undertaken in good…”
Matter of Est. of Stephens, 574 P.2d 67 (Ariz. Ct. App. 1978). “(Emphasis in original) With this in mind, A.R.S. § 14-3720 allows for compensation to a personal representative for reasonable attorney’s fees incurred in prosecuting or defending an action in good faith on behalf of the estate.”
Matter of Est. of Wright, 647 P.2d 1153 (Ariz. Ct. App. 1982). “See Also A.R.S. § 14-3720 (authorizing reasonable attorney fees for defending or prosecuting any action on behalf of the personal representative).”
Gorman v. State ex rel. Owens, 155 P.3d 1054 (Ariz. Ct. App. 2007). “A.R.S. § 14-3720 (2005). We therefore award Gorman his necessary expenses and reasonable attorneys’ fees from the estate upon his compliance with Rule 21(a), Arizona Rules of Civil Appellate Procedure.”
In Re Est. of Shumway, 3 P.3d 977 (Ariz. Ct. App. 2000). “section 14-3720 (1995), which allows an award of fees to a personal *987 representative who defends a will in good faith.”
Matter of Est. of Shano, 869 P.2d 1203 (Ariz. Ct. App. 1993). “section 14-3720, the estate will not be required to pay fees caused by malfeasance of the personal representative.”
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