Indiana Code

Ind. Code § 30-4-3-10 (2026)

Liability to third persons

✓ current as of May 2026
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     Sec. 10. (Liability to Third Persons)

     (a) Unless the terms of the contract or other non-negotiable obligation expressly provide otherwise, the trustee is not personally liable on a contract or other non-negotiable obligation with a third person made by him in the administration of the trust.

     (b) When a third person is entitled to compensation for injury suffered in the course of the administration of the trust:

     (1) If the injury is the result of the trustee's personal act or omission as trustee, the trustee will be personally liable and the injured party will be entitled to satisfaction of his claim from the trustee's individual property first and then, to the extent the claim is yet unsatisfied, from the trust estate.

     (2) If the injury is the result of the act or omission of an agent of the trustee, and the agent was properly selected and supervised and there was no improper delegation of authority to the agent, the injured party will be entitled to satisfaction of his claim from the trust estate first and then, to the extent that the claim is yet unsatisfied, from the trustee's individual property.

     (3) If the injury is the result of the act or omission of the settlor or his agent, and not that of the trustee or his agent, the injured party will be entitled to satisfaction of his claim from the trust estate and not from the trustee's individual property.

     (4) The question of ultimate liability as between the trust estate and the trustee individually, if it is to be determined, shall be determined in a proceeding for accounting, surcharge or indemnification.

Formerly: Acts 1971, P.L.416, SEC.4.

 

Notes of Decisions
Cited in 6 cases (2 in the last 5 years), 1980–2025 · leading case: Gen. Am. Life Ins. Co. v. Lee Castonguay, Jerry Fitzpatrick, Charles Kilmer Alex G. Sieben, 984 F.2d 1518 (9th Cir. 1993).
Gen. Am. Life Ins. Co. v. Lee Castonguay, Jerry Fitzpatrick, Charles Kilmer Alex G. Sieben, 984 F.2d 1518 (9th Cir. 1993). “§ 53-12-199; Idaho Code § 15-7-306 ; Ind.Code § 30-4-3-10; Ky.Rev.Stat.Ann. § 386.”
First Bank of Whiting v. Sisters of Mercy Health Corp., 545 N.E.2d 1134 (Ind. Ct. App. 1989). · cites it 2× “CODE § 30-4-3-10(b)(1), which imposes personal liability on a trustee for injuries suffered by third parties in the course of the administration of the trust.”
Donahue v. Watson, 413 N.E.2d 974 (Ind. Ct. App. 1980). “This principle of law has been codified in our Trust Code, Ind. Code 30-4-3-10(a): “Unless the terms of the contract or other non-negotiable obligation expressly provide otherwise, the trustee is not personally liable on a contract or other non-negotiable obligation with a third…”
LeSEA Inc v. LeSEA Broad. Corp. (N.D. Ind. 2025). · cites it 2× “] 17 Under Indiana Code § 30-4-3-10(b)(1), third parties like Defendants “are entitled to compensation for injury suffered in the course of the administration of the trust” from a trustee like Lester Sumrall when the “injury is the result of the trustee’s personal act or…”
Milan D. Zavodny, Tr. of the Milan D. Zavodny Trust v. Evelyn Ann Pavillonis Trust U/W/A, Dated 18 March 1997 (Ind. Ct. App. 2012). · cites it 2× “Trustee Status Ind. Code § 30-4-3-10 provides in part that unless the terms of a contract expressly provide otherwise, a trustee is not personally liable on a contract with a third person made in the administration of the trust.”
Marriage of Wendt & Pullen (Cal. Ct. App. 2021). “” (Ind. Code 30-4-3-10.) There is no decision in either state holding a spendthrift trust is immune from paying debts related to the administration of the trust, and we see no reason for recognizing such an exemption.”
— Ind. Code § 30-4-3-10(a) — 1 case
Donahue v. Watson, 413 N.E.2d 974 (Ind. Ct. App. 1980). “This principle of law has been codified in our Trust Code, Ind. Code 30-4-3-10(a): “Unless the terms of the contract or other non-negotiable obligation expressly provide otherwise, the trustee is not personally liable on a contract or other non-negotiable obligation with a third…”
— Ind. Code § 30-4-3-10(b)(1) — 2 cases
First Bank of Whiting v. Sisters of Mercy Health Corp., 545 N.E.2d 1134 (Ind. Ct. App. 1989). “CODE § 30-4-3-10(b)(1), which imposes personal liability on a trustee for injuries suffered by third parties in the course of the administration of the trust.”
LeSEA Inc v. LeSEA Broad. Corp. (N.D. Ind. 2025). “] 17 Under Indiana Code § 30-4-3-10(b)(1), third parties like Defendants “are entitled to compensation for injury suffered in the course of the administration of the trust” from a trustee like Lester Sumrall when the “injury is the result of the trustee’s personal act or…”
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