Oregon Revised Statutes

Or. Rev. Stat. § 115.005 (2026)

Presentation of claims; time limitations

✓ current as of May 2026
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      115.005 Presentation of claims; time limitations. (1)(a) Claims against the estate of a decedent, other than claims of the personal representative as a creditor of the decedent, shall be presented to the personal representative. Filing a claim with the court does not constitute presentation to the personal representative. Except as provided in paragraph (b) of this subsection, a claim is presented to the personal representative when the claim is mailed or personally delivered to the personal representative at:

      (A) The address for the personal representative included in the petition for appointment of the personal representative under ORS 113.035;

      (B) The address provided for presentation of claims under ORS 115.003; or

      (C) The address provided for presentation of claims in the published notice under ORS 113.155 or 113.225.

      (b) In addition to the addresses for the presentation of claims under paragraph (a) of this subsection, the personal representative may authorize creditors to present claims by electronic mail or facsimile communication to a designated electronic mail address or facsimile number. If the personal representative authorizes alternative methods of presentation under this subsection, a claim is presented to the personal representative when it is sent to the electronic mail address or the facsimile number designated by the personal representative for the presentation of claims, unless the sender receives a notice that the electronic mail was not delivered or the facsimile communication was not successful. If the personal representative denies receiving the electronic mail or facsimile communication, the burden of proof is on the creditor to demonstrate that the electronic mail was properly addressed and sent or that the facsimile communication was properly addressed and successfully delivered or transmitted.

      (2) Except as provided in subsection (3) of this section, a claim is barred from payment from the estate if not presented within the statute of limitations applicable to the claim and before the later of:

      (a) Four months after the date of publication of notice to interested persons; or

      (b) If the claim was one with respect to which the personal representative was required to deliver or mail a notice under ORS 115.003 (2), 45 days after a notice meeting the requirements of ORS 115.003 (3) is delivered or mailed to the last-known address of the person asserting the claim.

      (3) A claim against the estate presented after claims are barred under subsection (2) of this section shall be paid from the estate if the claim:

      (a) Is presented before the expiration of the statute of limitations applicable to the claim and before the personal representative files the final account;

      (b) Is presented by a person who did not receive a notice under ORS 115.003 mailed or delivered more than 30 days prior to the date on which the claim is presented and who is not an assignee of a person who received such notice; and

      (c) Would be allowable but for the time at which the claim is presented.

      (4) A claim against an estate may be paid under subsection (3) of this section only after payment of all expenses having priority over claims under ORS 115.125 and payment of all previously presented claims.

      (5) This section does not affect or prevent:

      (a) Any proceeding to enforce a mortgage, pledge or other lien upon property of the estate, or to quiet title or reform any instrument with respect to title to property; or

      (b) To the limits of the insurance protection only, any proceeding to establish liability of the decedent or the personal representative for which the decedent or personal representative is protected by liability insurance at the time the proceeding is commenced. [1969 c.591 §141; 1973 c.506 §29; 1989 c.229 §4; 1993 c.214 §1; 2001 c.620 §3; 2003 c.523 §1; 2017 c.169 §27; 2023 c.18 §8]

Notes of Decisions
Cited in 15 cases, 1976–2017 · leading case: Willbanks v. Goodwin, 689 P.2d 1004 (Or. Ct. App. 1984).
Willbanks v. Goodwin, 689 P.2d 1004 (Or. Ct. App. 1984). · cites it 7× “Defendants’ first two assignments of error are the trial court’s denial of their motion to dismiss plaintiffs complaint on the ground that it was time barred under ORS 115.005 and its granting of plaintiffs motion to strike defendant’s affirmative defense of the statute of…”
Ramirez v. Lembcke, 80 P.3d 510 (Or. Ct. App. 2003). · cites it 3× “ORS 115.005 provides, in part: *76 (Emphasis added.”
Willbanks v. Goodwin, 709 P.2d 213 (Or. 1985). · cites it 3× “1 ORS 115.005 provides: “(1) Claims against the estate of a decedent, other than claims of the personal representative as a creditor of the decedent, shall be presented to the personal representative.”
Rawls v. Evans, 48 P.3d 159 (Or. Ct. App. 2002). · cites it 3× “Next, appellants argue that Zollman’s claim was time barred under the two-year statute of limitations in ORS 115.005(4). 1 Evans died in 1995. In that same year, the trial court determined that Zollman’s earnest money agreement *84 was enforceable and that the personal…”
Hein v. Thiel, 549 P.2d 514 (Or. 1976). · cites it 3× “because plaintiff "failed to comply with the estate claim procedures” required by ORS 115.005 and 115.025. 1 More specifically, defendant contends that the letter which plaintiff’s attorney wrote to defendant’s attorney failed to satisfy the requirements of these statutes in…”
Wilson v. Culbertson, 599 P.2d 1163 (Or. Ct. App. 1979). · cites it 3× “Defendant filed a plea in abatement, contending that the claim against the estate was barred because it had not first been presented to the personal representative as required by ORS 115.005(1). The district court sustained the plea in abatement because it concluded that…”
State ex rel. Dep't of Human Servs. v. Broyles, 208 P.3d 519 (Or. Ct. App. 2009). · cites it 8× “004(5), whichever is earlier); ORS 115.005(2) (requiring compliance with both the statute of limitations applicable to the claim and the time limitations in ORS 115.”
State v. Cue, 342 P.3d 98 (Or. Ct. App. 2014). · cites it 16× “We conclude that the trial court erred when it granted summary judgment in favor of defendant for the reason that OHA had failed to satisfy the condition of ORS 115.005 (3)(b). Accordingly, we reverse and remand.”
First Interstate Bank v. Haynes, 699 P.2d 1168 (Or. Ct. App. 1985). “A claim on a debt, whether absolute or contingent, is presented to an estate in the manner provided in ORS 115.005. If the claim is disallowed, the claimant has 30 days within which to request a summary determination of the claim or to commence a separate action against the…”
State Ex Rel. Dept. of Hs v. Broyles, 208 P.3d 519 (Or. Ct. App. 2009). · cites it 9× “" [4] ORS 115.005 provides, in part: "(2) Except as provided in subsection (3) of this section, a claim is barred from payment from the estate if not presented within the statute of limitations applicable to the claim and before the later of: "(a) Four months after the date of…”
Thomas v. State ex rel. Senior & Disabled Servs. Div., 878 P.2d 1081 (Or. 1994). · cites it 4× “075 (claims for debts not yet due may be presented and allowed at their present value, facilitating settling the estate before future debts become due); ORS 115.005(4) (“[c]laims not presented within two years of the death of the decedent or within the applicable statute of…”
Thomas v. Senior & Disabled Serv. Div., 878 P.2d 1081 (Or. 1994). · cites it 4× “075 (claims for debts not yet due may be presented and allowed at their present value, facilitating settling the estate before future debts become due); ORS 115.005(4) ("[c]laims not presented within two years of the death of the decedent or within the applicable statute of…”
— Or. Rev. Stat. § 115.005(1) — 4 cases
Wilson v. Culbertson, 599 P.2d 1163 (Or. Ct. App. 1979). “Defendant filed a plea in abatement, contending that the claim against the estate was barred because it had not first been presented to the personal representative as required by ORS 115.005(1). The district court sustained the plea in abatement because it concluded that…”
Ramirez v. Lembcke, 80 P.3d 510 (Or. Ct. App. 2003). “ORS 115.005 provides, in part: *76 (Emphasis added.”
Willbanks v. Goodwin, 689 P.2d 1004 (Or. Ct. App. 1984). “Defendants’ first two assignments of error are the trial court’s denial of their motion to dismiss plaintiffs complaint on the ground that it was time barred under ORS 115.005 and its granting of plaintiffs motion to strike defendant’s affirmative defense of the statute of…”
Hein v. Thiel, 549 P.2d 514 (Or. 1976). “because plaintiff "failed to comply with the estate claim procedures” required by ORS 115.005 and 115.025. 1 More specifically, defendant contends that the letter which plaintiff’s attorney wrote to defendant’s attorney failed to satisfy the requirements of these statutes in…”
— Or. Rev. Stat. § 115.005(2) — 3 cases
State ex rel. Dep't of Human Servs. v. Broyles, 208 P.3d 519 (Or. Ct. App. 2009). “004(5), whichever is earlier); ORS 115.005(2) (requiring compliance with both the statute of limitations applicable to the claim and the time limitations in ORS 115.”
State v. Cue, 342 P.3d 98 (Or. Ct. App. 2014). “We conclude that the trial court erred when it granted summary judgment in favor of defendant for the reason that OHA had failed to satisfy the condition of ORS 115.005 (3)(b). Accordingly, we reverse and remand.”
State Ex Rel. Dept. of Hs v. Broyles, 208 P.3d 519 (Or. Ct. App. 2009). “" [4] ORS 115.005 provides, in part: "(2) Except as provided in subsection (3) of this section, a claim is barred from payment from the estate if not presented within the statute of limitations applicable to the claim and before the later of: "(a) Four months after the date of…”
— Or. Rev. Stat. § 115.005(2)(a) — 2 cases
State ex rel. Dep't of Human Servs. v. Broyles, 208 P.3d 519 (Or. Ct. App. 2009). “004(5), whichever is earlier); ORS 115.005(2) (requiring compliance with both the statute of limitations applicable to the claim and the time limitations in ORS 115.”
State Ex Rel. Dept. of Hs v. Broyles, 208 P.3d 519 (Or. Ct. App. 2009). “" [4] ORS 115.005 provides, in part: "(2) Except as provided in subsection (3) of this section, a claim is barred from payment from the estate if not presented within the statute of limitations applicable to the claim and before the later of: "(a) Four months after the date of…”
— Or. Rev. Stat. § 115.005(3) — 4 cases
Willbanks v. Goodwin, 709 P.2d 213 (Or. 1985). “1 ORS 115.005 provides: “(1) Claims against the estate of a decedent, other than claims of the personal representative as a creditor of the decedent, shall be presented to the personal representative.”
Willbanks v. Goodwin, 689 P.2d 1004 (Or. Ct. App. 1984). “Defendants’ first two assignments of error are the trial court’s denial of their motion to dismiss plaintiffs complaint on the ground that it was time barred under ORS 115.005 and its granting of plaintiffs motion to strike defendant’s affirmative defense of the statute of…”
State v. Cue, 342 P.3d 98 (Or. Ct. App. 2014). “We conclude that the trial court erred when it granted summary judgment in favor of defendant for the reason that OHA had failed to satisfy the condition of ORS 115.005 (3)(b). Accordingly, we reverse and remand.”
Vermeer v. Bunyard, 695 P.2d 57 (Or. Ct. App. 1985).
— Or. Rev. Stat. § 115.005(3)(a) — 1 case
State v. Cue, 342 P.3d 98 (Or. Ct. App. 2014). “We conclude that the trial court erred when it granted summary judgment in favor of defendant for the reason that OHA had failed to satisfy the condition of ORS 115.005 (3)(b). Accordingly, we reverse and remand.”
— Or. Rev. Stat. § 115.005(3)(b) — 1 case
State v. Cue, 342 P.3d 98 (Or. Ct. App. 2014). “We conclude that the trial court erred when it granted summary judgment in favor of defendant for the reason that OHA had failed to satisfy the condition of ORS 115.005 (3)(b). Accordingly, we reverse and remand.”
— Or. Rev. Stat. § 115.005(3)(c) — 1 case
State v. Cue, 342 P.3d 98 (Or. Ct. App. 2014). “We conclude that the trial court erred when it granted summary judgment in favor of defendant for the reason that OHA had failed to satisfy the condition of ORS 115.005 (3)(b). Accordingly, we reverse and remand.”
— Or. Rev. Stat. § 115.005(4) — 4 cases
Rawls v. Evans, 48 P.3d 159 (Or. Ct. App. 2002). “Next, appellants argue that Zollman’s claim was time barred under the two-year statute of limitations in ORS 115.005(4). 1 Evans died in 1995. In that same year, the trial court determined that Zollman’s earnest money agreement *84 was enforceable and that the personal…”
Ramirez v. Lembcke, 80 P.3d 510 (Or. Ct. App. 2003). “ORS 115.005 provides, in part: *76 (Emphasis added.”
Thomas v. State ex rel. Senior & Disabled Servs. Div., 878 P.2d 1081 (Or. 1994). “075 (claims for debts not yet due may be presented and allowed at their present value, facilitating settling the estate before future debts become due); ORS 115.005(4) (“[c]laims not presented within two years of the death of the decedent or within the applicable statute of…”
Thomas v. Senior & Disabled Serv. Div., 878 P.2d 1081 (Or. 1994). “075 (claims for debts not yet due may be presented and allowed at their present value, facilitating settling the estate before future debts become due); ORS 115.005(4) ("[c]laims not presented within two years of the death of the decedent or within the applicable statute of…”
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.