California Codes

Cal. Probate Code § 8570 (2026)

✓ current as of May 2026

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As used in this article, “nonresident personal representative” means a nonresident of this state appointed as personal representative, or a resident of this state appointed as personal representative who later removes from and resides without this state.

Notes of Decisions

Cited in 3 cases (1 in the last 5 years), 1998–2021 · leading case: Condon v. McHenry, 98 Cal. Daily Op. Serv. 5986 (Cal. Ct. App. 1998).

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Condon v. McHenry, 98 Cal. Daily Op. Serv. 5986 (Cal. Ct. App. 1998). · cites it 3× “After hearing argument, he concluded that, by serving as counsel for the co-executor of a will written for a California decedent, which devised California property, and was subject to *1142 California probate proceedings, Katz, a nonmember of the State Bar, had “practice[d] law…”

Hassanati v. Int'l Lease Fin. Corp., 51 F. Supp. 3d 887 (C.D. Cal. 2014). “35 These plaintiffs have not filed a statement of permanent address with the court, Cal. PROB. Code § 8570 , nor have they shown that they are the executors or successor executors of their decedent’s will, id.”

Vosburg v. Harrison CA4/2 (Cal. Ct. App. 2021). “(Prob. Code, § 8570.) If serving as an executor is not the type of act that would even suggest residence within the state, such act would clearly have even less relevance for the purpose of determining whether the 14 defendant can be characterized as “physically present” or…”

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