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Florida Statutes

Fla. Stat. § 733.6175 (2025)

Proceedings for review of employment of agents and compensation of personal representatives and employees of estate.

✓ 2025 Florida Statutes — current through the 2025 Regular Session
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733.6175 Proceedings for review of employment of agents and compensation of personal representatives and employees of estate.—
(1) The court may review the propriety of the employment of any person employed by the personal representative and the reasonableness of any compensation paid to that person or to the personal representative.
(2) Court proceedings to determine reasonable compensation of the personal representative or any person employed by the personal representative, if required, are a part of the estate administration process, and the costs, including attorneys’ fees, of the person assuming the burden of proof of propriety of the employment and reasonableness of the compensation shall be determined by the court and paid from the assets of the estate unless the court finds the requested compensation to be substantially unreasonable. The court shall direct from which part of the estate the compensation shall be paid.
(3) The burden of proof of propriety of the employment and the reasonableness of the compensation shall be upon the personal representative and the person employed. Any person who is determined to have received excessive compensation from an estate for services rendered may be ordered to make appropriate refunds.
(4) The court may determine reasonable compensation for the personal representative or any person employed by the personal representative without receiving expert testimony. Any party may offer expert testimony after notice to interested persons. If expert testimony is offered, a reasonable expert witness fee shall be awarded by the court and paid from the assets of the estate. The court shall direct from what part of the estate the fee shall be paid.
History.—s. 2, ch. 76-172; s. 1014, ch. 97-102; s. 143, ch. 2001-226.
Notes of Decisions
Cited in 39 cases (3 in the last 5 years), 1980–2023 · leading case: Amendments to the Florida Prob. Rules, 848 So. 2d 1069 (Fla. 2003).
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Amendments to the Florida Prob. Rules, 848 So. 2d 1069 (Fla. 2003). · cites it 10× “§ 733.6175, Fla. Stat. Proceedings for review of employment of agents and compensation of personal representatives and employees of estate.”
Kathleen G. Kozinski, etc. v. Amy Stabenow & Nora Faul, 152 So. 3d 650 (Fla. 4th DCA 2014). · cites it 11× “In Beck , the Third District said that “[the appellee]’s challenge to payment of that compensation invoked Section 733.6175, Florida Statutes (1977), which placed the burden of proof as to the propriety, reasonableness and necessity of such payments upon the personal…”
Beck v. Beck, 383 So. 2d 268 (Fla. 3d DCA 1980). · cites it 4× “§ 733.6175, Fla. Stat. (1977). [7] All of the powers conferred upon the personal representative under Section 733.”
Florida Bar, 537 So. 2d 500 (Fla. 1988). · cites it 4× “F.S. 733.6175 Proceedings for review of _ employment of agents and compensation of personal representatives and employees of estate.”
Winston v. Winston, 610 So. 2d 1323 (Fla. 4th DCA 1992). · cites it 4× “See § 733.6175, Fla.Stat. (1991); see also Sheffield v.”
In Re Amendments to the Fl. Prob. Rules, 964 So. 2d 140 (Fla. 2007). · cites it 6× “§ 733.6175, Fla. Stat. Proceedings for review of employment of agents and compensation of personal representatives and employees of estate.”
In Re Est. of Catapane, 759 So. 2d 9 (Fla. 4th DCA 2000). · cites it 2× “Under section 733.6175, Florida Statutes, the code provides for proceedings to review the personal representative's employment of agents upon the petition of an interested person bearing all or part of the impact of the payment of compensation to the agent.”
Bitterman v. Bitterman, 685 So. 2d 861 (Fla. 4th DCA 1996). · cites it 4× “6171, Florida Statutes (1993) along with section 733.6175, Florida Statutes (1993), the statute which governs proceedings to determine *866 the propriety of employment of agents by the personal representatives and the reasonableness of their fees.”
Faulkner v. Woodruff, 159 So. 3d 319 (Fla. 2d DCA 2015). · cites it 9× “2 He cited section 733.6175, Florida Statutes (2010), and Florida Probate Rule 5.”
In Re Amendments to the Florida Prob. Rules, 584 So. 2d 964 (Fla. 1991). · cites it 2× “§ 733.6175, Fla. Stat. Proceedings for review of employment of agents and compensation of personal representatives and employees of estate.”
Geary v. Butzel Long, P.C., 13 So. 3d 149 (Fla. 4th DCA 2009). · cites it 3× “Pursuant to section 733.6175(2), Florida Statutes: Court proceedings to determine reasonable compensation of the personal representative or any person employed by the personal representative, if required, are a part of the estate administration process, and the costs, including…”
Richardson v. Jones, 508 So. 2d 739 (Fla. 2d DCA 1987). · cites it 2× “Section 733.6175, Florida Statutes (1985), provides that "Any person who is determined to have received excessive compensation from an estate for services rendered may be ordered to make appropriate refunds.”
Show all 39 citing cases →
— 733.6175(1) — 1 case
Neal Simmons v. Est. of Dr. Adrienne S. Baranowitz & Merrill Lynch Trust Co., 189 So. 3d 819 (Fla. 4th DCA 2015).
— 733.6175(2) — 4 cases
Geary v. Butzel Long, P.C., 13 So. 3d 149 (Fla. 4th DCA 2009). “Pursuant to section 733.6175(2), Florida Statutes: Court proceedings to determine reasonable compensation of the personal representative or any person employed by the personal representative, if required, are a part of the estate administration process, and the costs, including…”
Bookman v. Davidson, 136 So. 3d 1276 (Fla. 1st DCA 2014).
Faulkner v. Woodruff, 159 So. 3d 319 (Fla. 2d DCA 2015). “2 He cited section 733.6175, Florida Statutes (2010), and Florida Probate Rule 5.”
Venis v. Greenspan, 833 So. 2d 208 (Fla. 4th DCA 2002).
— 733.6175(3) — 1 case
Neal Simmons v. Est. of Dr. Adrienne S. Baranowitz & Merrill Lynch Trust Co., 189 So. 3d 819 (Fla. 4th DCA 2015).
— 733.6175(4) — 2 cases
Foreman v. N. Trust Bank of Florida, N.A., 905 So. 2d 276 (Fla. 2d DCA 2005).
Baumann v. Est. of Blum, 898 So. 2d 1106 (Fla. 2d DCA 2005).
— 733.6175(8) — 1 case
Kathleen G. Kozinski, etc. v. Amy Stabenow & Nora Faul, 152 So. 3d 650 (Fla. 4th DCA 2014). “In Beck , the Third District said that “[the appellee]’s challenge to payment of that compensation invoked Section 733.6175, Florida Statutes (1977), which placed the burden of proof as to the propriety, reasonableness and necessity of such payments upon the personal…”
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