Oregon Revised Statutes

Or. Rev. Stat. § 111.275 (2026)

Limited judgments

✓ current as of May 2026

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111.275 Limited judgments. (1) The court in a probate proceeding may enter a limited judgment only for the following decisions of the court:

(a) A decision on a petition for appointment or removal of a personal representative, including a successor personal representative.

(b) A decision in a will contest filed in the probate proceeding.

(c) A decision to require delivery of possession of property of the decedent, including records, accounts or documents relating to the property.

(d) A decision to determine ownership of title for real or personal property.

(e) A decision on a petition or motion for support or elective share.

(f) A decision on an objection to a final accounting.

(g) A decision on a request made in the proceeding for a declaratory judgment under ORS 111.095.

(h) A decision on a request for an award of expenses under ORS 116.183.

(i) A decision on surcharge of a fiduciary or a surety.

(j) Such decisions of the court as may be specified by rules or orders of the Chief Justice of the Supreme Court under ORS 18.028.

(k) Any other decision that is a final determination of the rights of one or more persons.

(2) A court may enter a limited judgment under this section only if the court determines that there is no just reason for delay. The judgment document need not reflect the court’s determination that there is no just reason for delay. [2005 c.568 §33; 2009 c.50 §1; 2016 c.42 §18; 2021 c.282 §15]

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Notes of Decisions

Cited in 4 cases (2 in the last 5 years), 2006–2025 · leading case: Warkentin v. Shirey, 480 P.3d 289 (Or. Ct. App. 2020).

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Warkentin v. Shirey, 480 P.3d 289 (Or. Ct. App. 2020). · cites it 2× “Finally, the Court of Appeals concluded that the claim of error regarding personal representative fees is unreviewable because the requirements of a limited judgment under ORS 111.275(1)(e) have not been met. Affirmed.”

Jarratt v. Patterson, 337 Or. App. 590 (Or. Ct. App. 2025). “However, under ORS 111.275(2), relating to limited judgments in probate proceedings, “[t]he judgment document need not reflect the court’s determination that there is no just reason for delay.”

Jarratt v. Patterson, 337 Or. App. 590 (Or. Ct. App. 2025). “However, under ORS 111.275(2), relating to limited judgments in probate proceedings, “[t]he judgment document need not reflect the court’s determination that there is no just reason for delay.”

Slusarenko v. Slusarenko, 147 P.3d 920 (Or. Ct. App. 2006). “ORS 111.275. The trial court determined that the 1998 will was revoked by operation of law as a result of Jack and Wilma’s subsequent remarriage, but denied plaintiffs’ other grounds for contesting that will.”

— Or. Rev. Stat. § 111.275(1)(e) — 1 case

Warkentin v. Shirey, 480 P.3d 289 (Or. Ct. App. 2020). “Finally, the Court of Appeals concluded that the claim of error regarding personal representative fees is unreviewable because the requirements of a limited judgment under ORS 111.275(1)(e) have not been met. Affirmed.”

— Or. Rev. Stat. § 111.275(2) — 2 cases

Jarratt v. Patterson, 337 Or. App. 590 (Or. Ct. App. 2025). “However, under ORS 111.275(2), relating to limited judgments in probate proceedings, “[t]he judgment document need not reflect the court’s determination that there is no just reason for delay.”

Jarratt v. Patterson, 337 Or. App. 590 (Or. Ct. App. 2025). “However, under ORS 111.275(2), relating to limited judgments in probate proceedings, “[t]he judgment document need not reflect the court’s determination that there is no just reason for delay.”

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