Va. Code » Title 64.2. Wills, Trusts, and Fiduciaries » Subtitle III. Trusts » Chapter 7. Uniform Trust Code » Article 8. Duties and Powers of Trustee
Virginia Code

Va. Code Ann. § 64.2-765 (2026)

Impartiality

✓ current as of May 2026
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If a trust has two or more beneficiaries, the trustee shall act impartially in investing, managing, and distributing the trust property, giving due regard to the beneficiaries' respective interests.

2005, c. 935, § 55-548.03; 2012, c. 614.

Notes of Decisions
Cited in 7 cases (5 in the last 5 years), 2014–2025 · leading case: Rafalko v. Georgiadis, 777 S.E.2d 870 (Va. 2015).
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Rafalko v. Georgiadis, 777 S.E.2d 870 (Va. 2015). · cites it 22× “Partiality cannot be simply a form of bad faith because that would make Code § 64.2-765 duplicative of Code § 64.”
Kositzka, Wicks & Co., etc. v. Alfred C. Fick, etc. (Va. Ct. App. 2025). · cites it 4× “Breach of Fiduciary Duty KWC argues that the circuit court erred by misapplying three statutes in the Uniform Trust Code in concluding it owed a fiduciary duty to Ryan to avoid operation against him of the predeceased beneficiary provision: specifically, Code § 64.2-765 (duty of…”
Keil v. Seth Corp. (E.D. Va. 2021). · cites it 2× “” Va. Code Ann. § 64.2-765 . And, the beneficiaries to whom the trustee 14 owes these duties include more than simply current beneficiaries, as the Virginia Code applies to all beneficiaries, whether vested or contingent.”
Stavros P. Galiotos, Individually, etc. v. Tasos A. Galiotos, Individually, etc. (Va. Ct. App. 2024). · cites it 2× “” Code § 64.2-765; see also Code § 64.2-777(B) (“The exercise of a power is subject to the fiduciary duties prescribed by this article.”
Paul Galiotos, Individually, etc. v. Tasos A. Galiotos, Individually, etc. (Va. Ct. App. 2024). · cites it 2× “” Code § 64.2-765; see also Code § 64.2-777(B) (“The exercise of a power is subject to the fiduciary duties prescribed by this article.”
Trimmer v. Savage, 89 Va. Cir. 135 (Henrico Cir. Ct. 2014). · cites it 3× “See Va. Code § 64.2-765, “In the management of trust property, a trustee should always conduct himself with strict neutrality, favoring none of the parties, and endeavor to obtain an impartial direction in all cases of doubt or difficulty.”
R.B. v. C.C. (Mass. App. Ct. 2023). “, Va. Code Ann. § 64.2-765 (duty of impartiality); Va.”
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