Florida Statutes

Fla. Stat. § 733.903 (2025)

Subsequent administration.

✓ 2025 Florida Statutes — current through the 2025 Regular Session

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733.903 Subsequent administration.—The final settlement of an estate and the discharge of the personal representative shall not prevent further administration. The order of discharge may not be revoked based upon the discovery of a will or later will.

History.—s. 1, ch. 74-106; s. 96, ch. 75-220; s. 1, ch. 88-110; s. 169, ch. 2001-226.

Note.—Created from former s. 734.26.

Notes of Decisions

Cited in 21 cases (2 in the last 5 years), 1980–2026 · leading case: Van Dusen v. Se. First Nat. Bank, 478 So. 2d 82 (Fla. 3d DCA 1985).

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Van Dusen v. Se. First Nat. Bank, 478 So. 2d 82 (Fla. 3d DCA 1985). · cites it 4× “[15] Section 733.903, Florida Statutes (1983), which provides for the reopening of estates, is not applicable in this case because there is nothing further to administer.”

The Sampson Farm Ltd. P'ship v. Parmenter, 238 So. 3d 387 (Fla. 3d DCA 2018). · cites it 2× “On September 4, 2014, Parmenter, as former personal representative, filed a petition to reopen the Estate pursuant to section 733.903, Florida Statutes (2014), “solely for the purpose of doing additional procedures necessary in order to clarify distributions.”

In Re Est. of Killinger, 448 So. 2d 1187 (Fla. 2d DCA 1984). · cites it 6× “A petition to reopen and readminister the estate was filed pursuant to section 733.903, Florida Statutes (1981), which allows revocation of an order of discharge "if it becomes necessary that further administration of the estate be had for any cause.”

Payette v. Clark, 559 So. 2d 630 (Fla. 2d DCA 1990). · cites it 3× “Second, the petition can be maintained under section 733.903, Florida Statutes (1987).”

Amendments to the Florida Prob. Rules, 848 So. 2d 1069 (Fla. 2003). · cites it 2× “Statutory Reference § 733.903, Fla. Stat. Subsequent administration.”

Yellen v. Long, 387 So. 2d 384 (Fla. 4th DCA 1980). · cites it 2× “Assuming that probate proceedings may be reopened under Section 733.903, Florida Statutes (1979), or pursuant to the inherent power and authority of the court where strong factual allegations of fraud, overreaching or mistake are made, as suggested by dicta in Padgett v.”

Florida Bar, 537 So. 2d 500 (Fla. 1988). “Statutory Reference F.S. 733.903 Subsequent administration. RULE 5.”

Elmowitz v. Est. of Zimmerman, 647 So. 2d 1064 (Fla. 3d DCA 1994). · cites it 2× “[2] We note that under section 733.903, Florida Statutes (1988) an estate may be reopened for good cause shown.”

Dribin v. Est. of Nolan, 801 So. 2d 249 (Fla. 4th DCA 2001). · cites it 3× “Additionally, section 733.903, Florida Statutes, provides that the final settlement of an estate and discharge of the personal representative shall not prevent a revocation of the order of discharge or the subsequent issuance of letters if other property of the estate is…”

Carraway v. Carraway, 883 So. 2d 834 (Fla. 1st DCA 2004). “Although section 733.903 and Florida Probate Rule 5.”

Florida Bar re Amendment to Rules, 458 So. 2d 1079 (Fla. 1984). “Statutory Reference F.S. 733.903 Subsequent administration. Rule 5.”

MacIer v. Est. of Bessie Giamportone, 972 So. 2d 1017 (Fla. 4th DCA 2008). · cites it 2× “Inasmuch as the probate judge had jurisdiction and the power to re-open the Estate under section 733.903, Florida Statutes (2007), as well as the authority to protect an alleged property interest of the Estate, we affirm.”

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