Pennsylvania Consolidated Statutes

20 Pa. Cons. Stat. § 3182 (2026)

 Grounds for removal.

✓ current as of May 2026
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§ 3182.  Grounds for removal.

The court shall have exclusive power to remove a personal representative when he:

(1)  is wasting or mismanaging the estate, is or is likely to become insolvent, or has failed to perform any duty imposed by law; or

(2)  (Deleted by amendment).

(3)  has become incapacitated to discharge the duties of his office because of sickness or physical or mental incapacity and his incapacity is likely to continue to the injury of the estate; or

(4)  has removed from the Commonwealth or has ceased to have a known place of residence therein, without furnishing such security or additional security as the court shall direct; or

(4.1)  has been charged with voluntary manslaughter or homicide, except homicide by vehicle, as set forth in sections 3155 (relating to persons entitled) and 3156 (relating to persons not qualified), provided that the removal shall not occur on these grounds if the charge has been dismissed, withdrawn or terminated by a verdict of not guilty; or

(5)  when, for any other reason, the interests of the estate are likely to be jeopardized by his continuance in office.

(Apr. 16, 1992, P.L.108, No.24, eff. 60 days; Dec. 20, 2000, P.L.838, No.118, eff. 60 days)

 

2000 Amendment.  Act 118 added par. (4.1).

1992 Amendment.  See section 21 of Act 24 in the appendix to this title for special provisions relating to applicability.

Cross References.  Section 3182 is referred to in sections 5131, 5515 of this title.

Notes of Decisions
Cited in 27 cases (6 in the last 5 years), 1978–2025 · leading case: In Re Francis Edward McGillick Found., 642 A.2d 467 (Pa. 1994).
In Re Francis Edward McGillick Found., 642 A.2d 467 (Pa. 1994). · cites it 6× “Nonetheless, trustees are not judged by an ideal standard, but by the standard set forth in 20 Pa.C.S. § 3182 (grounds for removal of personal representative), made applicable to trustees by 20 Pa.”
In Re White, 484 A.2d 763 (Pa. 1984). · cites it 4× “20 Pa.C.S. § 3182 [3] . The beneficiaries contend that White's action had the potential of mismanaging the trust, thereby jeopardizing it.”
In re Est. of Andrews, 92 A.3d 1226 (Pa. Super. Ct. 2014). · cites it 2× “The grounds for removal of a personal representative are delineated in 20 Pa.C.S. § 3182. That statute allows the orphans’ court to replace a personal representative when he or she “is wasting or mismanaging the estate, is or is likely to become insolvent, or has failed to…”
Three Keys Ltd. v. SR Util. Holding Co., 540 F.3d 220 (3rd Cir. 2008). “” 20 Pa. Cons.Stat. § 3182. While the action to remove Basciano and Palmer as executors was pending, Basciano personally received a payment of $220,000 that was due to the Estate for the sale of an Estate-owned shopping center, again without obtaining approval from the Orphans’…”
In Re Est. of Croessant, 393 A.2d 443 (Pa. 1978). · cites it 2× “See Section 3182 of the Probate, Estates and Fiduciaries Code, 20 Pa.C.S. § 3182 (1975); Quinlan Estate, 441 Pa.”
Hansel v. Hansel, 446 A.2d 1294 (Pa. Super. Ct. 1982). “July 1, 1972, 20 Pa.C.S. § 3182. 3 . Photocopies of the cancelled checks representing each of these transactions are attached to appellant’s original complaint.”
In Re Est. of Gadiparthi, 632 A.2d 942 (Pa. Commw. Ct. 1993). “Section 3182 of the Probate, Estate and Fiduciaries Code (Code), 20 Pa.C.S. § 3182, provides that the court has the authority to remove an administrator when the interests of the estate are likely to be jeopardized by his continuance in office.”
Est. of Zerbey, 392 A.2d 1340 (Pa. 1978). “See 20 Pa.C.S. §§ 3182(1), 7121; Holmes’ Trust, supra ; McCaskey’s Estate, 293 Pa.”
In re Camillo, 16 Pa. D. & C.5th 129 (2010). · cites it 2× “The attorney for the petitioner, Joseph Go wan, Esquire, offered 18 exhibits, which were entered into evidence as P-1 through P-18. The attorney for the respondent, Edward Gilson, Esquire, offered 6 exhibits, which were entered into evidence as R-l through R-6.”
Est. of: Whitehead, J. (Pa. Super. Ct. 2017). · cites it 4× “First, he contends that the orphans’ court misapplied 20 Pa.C.S. § 3182 (“Grounds for removal”) and 20 Pa.”
Est. of: Zupancic, D., Appeal of: Zupancic, A. (Pa. Super. Ct. 2025). · cites it 3× “On September 11, 2024, a Petition to Remove Co-Executors in Accordance with 20 Pa.C.S. § 3182 for Failure to Perform Fiduciary Duties (“petition”) was filed by Attorney Jeffrey P.”
In Re: Kocis, M. An Incapacitated Person (Pa. Super. Ct. 2016). · cites it 2× “However, the orphans’ court permitted Elizabeth to serve as ____________________________________________ 3 While 20 Pa.C.S. § 3182 details the grounds for removal of a personal representative in a decedent’s estate, it is also applicable to the removal of a guardian of an…”
— 20 Pa. Cons. Stat. § 3182(1) — 8 cases
Est. of Zerbey, 392 A.2d 1340 (Pa. 1978). “See 20 Pa.C.S. §§ 3182(1), 7121; Holmes’ Trust, supra ; McCaskey’s Estate, 293 Pa.”
In re Camillo, 16 Pa. D. & C.5th 129 (2010). “The attorney for the petitioner, Joseph Go wan, Esquire, offered 18 exhibits, which were entered into evidence as P-1 through P-18. The attorney for the respondent, Edward Gilson, Esquire, offered 6 exhibits, which were entered into evidence as R-l through R-6.”
Est. of: Whitehead, J. (Pa. Super. Ct. 2017). “First, he contends that the orphans’ court misapplied 20 Pa.C.S. § 3182 (“Grounds for removal”) and 20 Pa.”
— 20 Pa. Cons. Stat. § 3182(1)(5) — 1 case
In re Est. of Andrews, 92 A.3d 1226 (Pa. Super. Ct. 2014). “The grounds for removal of a personal representative are delineated in 20 Pa.C.S. § 3182. That statute allows the orphans’ court to replace a personal representative when he or she “is wasting or mismanaging the estate, is or is likely to become insolvent, or has failed to…”
— 20 Pa. Cons. Stat. § 3182(3) — 1 case
In Re Est. of Croessant, 393 A.2d 443 (Pa. 1978). “See Section 3182 of the Probate, Estates and Fiduciaries Code, 20 Pa.C.S. § 3182 (1975); Quinlan Estate, 441 Pa.”
— 20 Pa. Cons. Stat. § 3182(5) — 4 cases
In Re: Kocis, M. An Incapacitated Person (Pa. Super. Ct. 2016). “However, the orphans’ court permitted Elizabeth to serve as ____________________________________________ 3 While 20 Pa.C.S. § 3182 details the grounds for removal of a personal representative in a decedent’s estate, it is also applicable to the removal of a guardian of an…”
In Re: The Est. of Uschock, I. (Pa. Super. Ct. 2018).
Est. of Elliot (Mont. 2023).
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