Ohio Revised Code

Ohio Rev. Code § 5802.01 (2026)

Judicial intervention in trust administration

✓ laws through the 2026 session (checked Sept. 2026)
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(A) A court may intervene in the administration of a trust to the extent its jurisdiction is invoked by an interested person or as provided by law.

(B) An inter vivos trust is not subject to continuing judicial supervision unless ordered by the court. Trusts created pursuant to a section of the Revised Code or a judgment or decree of a court are subject to continuing judicial supervision to the extent provided by the section, judgment, or decree or by court order.

(C) A judicial proceeding involving a trust may relate to any matter involving the trust's administration, including a request for instructions and an action to declare rights.

Notes of Decisions
Cited in 8 cases (2 in the last 5 years), 2010–2026 · leading case: Dueck v. Clifton Club Co., 2017-Ohio-7161, 95 N.E.3d 1032.
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Dueck v. Clifton Club Co., 2017-Ohio-7161, 95 N.E.3d 1032. · cites it 2× “At the time appellants requested that the Trustees file an action to declare the legal rights to Beach access, the Trustees could have petitioned the court for direction regarding interpretation of the Trust Deed pursuant to R.”
Kidd v. Alfano, 2016-Ohio-7519, 64 N.E.3d 1052. “” R.C. 5802.01(B). The trust simply was not required to seek judicial approval of its discretionary decision to pay attorney fees.”
Zook v. JPMorgan Chase Bank, 2017-Ohio-838, 85 N.E.3d 1197. “The first option is a judicial proceeding under R.C. 5802.01 and Nos. 15AP-750 & 15AP-751 9 2721.”
In re Roudebush Trust, 2021-Ohio-4557, 182 N.E.3d 445. · cites it 3× “{¶17} Appellees Beverly and Martin agree, and add that the probate court’s intervention in the administration of the Trust is limited because R.C. 5802.01 restricts the court’s intervention “to the extent its jurisdiction is invoked by an interested party or as provided by law.”
In re Cletus P. McCauley & Mary A. McCauley Irrevocable Trust, 2014-Ohio-3489. “R.C. 5802.01: *** (B) An inter vivos trust is not subject to continuing judicial supervision unless ordered by the court.”
Kormanik v. Cooper, 941 N.E.2d 110 (Ohio Ct. App. 10th Dist. 2010). “The McGivney Trust also filed memoranda opposing the state defendants’ motions to dismiss, arguing that R.C. 5802.01(C) conferred on the probate court the authority to declare rights under a *187 trust established by the court and that the claims included a request for such a…”
In re McCauley Irrevocable Trust, 2014-Ohio-3692. “R.C. 5802.01: *** (B) An inter vivos trust is not subject to continuing judicial supervision unless ordered by the court.”
Marcinkevicius v. Galloway, 2026-Ohio-1280. “R.C. 5802.01(A) provides that “[a] court may intervene in the administration of a trust to the extent its jurisdiction is invoked by an interested person or as provided by law.”
Ohio Rev. Code § 5802.01(A): 1 case
Marcinkevicius v. Galloway, 2026-Ohio-1280. “R.C. 5802.01(A) provides that “[a] court may intervene in the administration of a trust to the extent its jurisdiction is invoked by an interested person or as provided by law.”
Ohio Rev. Code § 5802.01(B): 1 case
Kidd v. Alfano, 2016-Ohio-7519, 64 N.E.3d 1052. “” R.C. 5802.01(B). The trust simply was not required to seek judicial approval of its discretionary decision to pay attorney fees.”
Ohio Rev. Code § 5802.01(C): 2 cases
Kormanik v. Cooper, 941 N.E.2d 110 (Ohio Ct. App. 10th Dist. 2010). “The McGivney Trust also filed memoranda opposing the state defendants’ motions to dismiss, arguing that R.C. 5802.01(C) conferred on the probate court the authority to declare rights under a *187 trust established by the court and that the claims included a request for such a…”
In re Roudebush Trust, 2021-Ohio-4557, 182 N.E.3d 445. “{¶17} Appellees Beverly and Martin agree, and add that the probate court’s intervention in the administration of the Trust is limited because R.C. 5802.01 restricts the court’s intervention “to the extent its jurisdiction is invoked by an interested party or as provided by law.”
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