Ohio Rev. Code » Chapter 2113
Ohio Revised Code

Ohio Rev. Code § 2113.15 (2026)

Special administrator

✓ current as of May 2026
Find cases: SyfertCases citing this section ORCcodes.ohio.gov (official) Justiaon Justia CornellLII Search CasesGoogle Scholar
Effective:
January 13, 2012
Latest Legislation:
Senate Bill 124 - 129th General Assembly
PDF:
Download Authenticated PDF
 

When there is delay in granting letters testamentary or of administration, the probate court may appoint a special administrator to collect and preserve the effects of the deceased and grant the special administrator any other authority that the court considers appropriate.

The special administrator shall collect the assets and debts of the deceased and preserve them for the executor or administrator who thereafter is appointed. For that purpose the special administrator may begin, maintain, or defend suits as administrator and also sell any assets the court orders sold. The special administrator shall be allowed the compensation for the special administrator's services that the court thinks reasonable, if the special administrator faithfully fulfills the fiduciary duties.
Notes of Decisions
Cited in 7 cases (2 in the last 5 years), 1955–2026 · leading case: In re Est. of Parks, 2024 Ohio 1841 (Ohio Ct. App. 2024).
Sort: Relevance Newest Treatment
In re Est. of Parks, 2024 Ohio 1841 (Ohio Ct. App. 2024). · cites it 6× “06; R.C. 2113.15; R.C. 2113.16; R.C. 2113.17.”
Shepherd of the Valley Lutheran Ret. Servs., Inc. v. Cesta, 2019 Ohio 415 (Ohio Ct. App. 2019). “2d 587 (1963), paragraph two of the syllabus; see R.C. 2113.15 ("[w]hen there is delay in granting letters testamentary or of administration, the probate court may appoint a special administrator to collect and preserve the effects of the deceased and grant the special…”
Yardley v. West Ohio Conf. of United Methodist Church, Inc., 742 N.E.2d 723 (Ohio Ct. App. 2000). “However, nothing precludes a creditor from serving as a special administrator.”
In re Est. of Fields, 2016 Ohio 5358 (Ohio Ct. App. 2016). “R.C. 2113.15. Where, however, there are “neither creditors of the estate nor beneficiaries of the will,” and where there are no assets or property belonging to the estate, there is “no purpose to be served by the appointment of a fiduciary.”
In re Est. of Fogle, 2026 Ohio 911 (Ohio Ct. App. 2026). · cites it 2× “” R.C. 2113.15. “The special administrator shall collect the assets and debts of the deceased and preserve them for the executor or administrator who thereafter is appointed.”
Wiesenmayer v. Vaspory, 2019 Ohio 1805 (Ohio Ct. App. 2019). “See R.C. 2113.15 and 2113.17. Effective September 6, 2016, the court appointed Wiesenmayer to act as full administrator, and one day later, ODM presented a claim against the estate in the amount of $27,018.”
Heekin v. Palmer, 138 N.E.2d 431 (Ohio Ct. App. 1955). · cites it 4× “Under Section 2113.15, Revised Code, provision is made for the appointment of a special administrator.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.