Pennsylvania Consolidated Statutes

20 Pa. Cons. Stat. § 7781 (2026)

Remedies for breach of trust - UTC 1001.

✓ current as of May 2026

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SUBCHAPTER I

LIABILITY OF TRUSTEES AND RIGHTS

OF PERSONS DEALING WITH TRUSTEES

Sec.

7781. Remedies for breach of trust - UTC 1001.

7782. Damages for breach of trust - UTC 1002.

7783. Damages in absence of breach - UTC 1003.

7784. (Reserved).

7785. Limitation of action against trustee.

7785.1. Nonjudicial account settlement.

7786. Reliance on trust instrument - UTC 1006.

7787. Event affecting administration or distribution - UTC 1007.

7788. Exculpation of trustee - UTC 1008.

7789. Beneficiary's consent, release or ratification - UTC 1009.

7790. Limitation on personal liability of trustee - UTC 1010.

7790.1. Interest as general partner - UTC 1011.

7790.2. Protection of person dealing with trustee - UTC 1012.

7790.3. Certification of trust - UTC 1013.

Cross References. Subchapter I is referred to in sections 7701, 7785.1 of this title.

§ 7781. Remedies for breach of trust - UTC 1001.

(a) What constitutes breach of trust.--(Deleted by amendment).

(b) Remedies.--To remedy a breach of trust that has occurred or may occur, the court may order any appropriate relief, including the following:

(1) Compelling the trustee to perform the trustee's duties.

(2) Enjoining the trustee from committing a breach of trust.

(3) Compelling the trustee to redress a breach of trust by paying money, restoring property or other means.

(4) Ordering a trustee to file an account.

(5) Taking any action authorized by Chapter 43 (relating to temporary fiduciaries).

(6) (Reserved).

(7) Removing the trustee as provided in section 7766 (relating to removal of trustee - UTC 706).

(8) Reducing or denying compensation to the trustee.

(9) Subject to section 7790.2 (relating to protection of person dealing with trustee - UTC 1012):

(i) voiding an act of the trustee;

(ii) imposing a lien or a constructive trust on trust property; or

(iii) tracing trust property wrongfully disposed of and recovering the property or its proceeds.

(10) (Reserved).

(July 15, 2024, P.L.786, No.64, eff. 90 days)

2024 Amendment. Act 64 deleted subsec. (a). See section 11 of Act 64 in the appendix to this title for special provisions relating to Uniform Trust Code.

Cross References. Section 7781 is referred to in section 7766 of this title.

Notes of Decisions

Cited in 8 cases (6 in the last 5 years), 2012–2024 · leading case: Lewis Ex Rel. Young v. Alexander, 685 F.3d 325 (3rd Cir. 2012).

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Lewis Ex Rel. Young v. Alexander, 685 F.3d 325 (3rd Cir. 2012). “” 20 Pa. Cons.Stat. Ann. § 7711. The court’s authority includes the power to remedy breaches of trust, remove the trustee, or terminate the trust.”

In Re: Trust of Holdship, M., 288 A.3d 919 (Pa. Super. Ct. 2023). · cites it 2× “”4 20 Pa.C.S. § 7781(a). “[N]ot every breach of trust justifies removal of the trustee[; rather, t]he breach must be ‘serious.”

Trust Under Agreement of Pauline O. Walker, 208 A.3d 472 (Pa. Super. Ct. 2019). “" 20 Pa.C.S. § 7781. In addition, Section 7783, which addresses damages in the absence of a breach, states "Absent a breach of trust, a trustee is not liable to a beneficiary for a loss or depreciation in the value of trust property or for not having made a profit.”

Williams, L. v. Geer, L. (Pa. Super. Ct. 2024). · cites it 2× “]” 20 Pa.C.S. § 7781(a). Duties of a trustee include a duty of loyalty to administer the trust in good faith and solely for the benefit of the beneficiaries.”

In Re: Trust of Holdship, M. (Pa. Super. Ct. 2022). “”4 20 Pa.C.S. § 7781(a). “[N]ot every breach of trust justifies removal of the trustee[; rather, t]he breach must be ‘serious.”

Martin, C. v. Paul, S. & Martin, C. (Pa. Super. Ct. 2023). “See 20 Pa.C.S. § 7781(b) (listing remedies that a court may order for a trustee’s breach of trust).”

Harp v. Police & Fire Credit Union (E.D. Pa. 2023). “See 20 Pa. C.S. § 7781 (defining breach of trust as “violation by a trustee of a duty the trustee owes to a beneficiary”).”

Trust Under Will of Ashton, A.; Apl of: Reed, E. (Pa. 2021). “20 Pa.C.S. §7781(b). [J-26-2021] - 17 Law Comment (“Beneficiaries and cotrustees have standing to bring a petition to remedy a breach of trust.”

— 20 Pa. Cons. Stat. § 7781(a) — 3 cases

In Re: Trust of Holdship, M., 288 A.3d 919 (Pa. Super. Ct. 2023). “”4 20 Pa.C.S. § 7781(a). “[N]ot every breach of trust justifies removal of the trustee[; rather, t]he breach must be ‘serious.”

In Re: Trust of Holdship, M. (Pa. Super. Ct. 2022). “”4 20 Pa.C.S. § 7781(a). “[N]ot every breach of trust justifies removal of the trustee[; rather, t]he breach must be ‘serious.”

Williams, L. v. Geer, L. (Pa. Super. Ct. 2024). “]” 20 Pa.C.S. § 7781(a). Duties of a trustee include a duty of loyalty to administer the trust in good faith and solely for the benefit of the beneficiaries.”

— 20 Pa. Cons. Stat. § 7781(b) — 2 cases

Martin, C. v. Paul, S. & Martin, C. (Pa. Super. Ct. 2023). “See 20 Pa.C.S. § 7781(b) (listing remedies that a court may order for a trustee’s breach of trust).”

— 20 Pa. Cons. Stat. § 7781(b)(9)(iii) — 1 case

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