Wills, Estates & Trusts,
California Courts of Appeal
Nov. 2, 2023
Appellate ruling limits appearances by trustees and executors in pro per
The recent case of Sanchez v. Peralta (filed 8/9/23, Sixth Appellate District) brings new clarity to the ability of fiduciaries to appear on their own behalf in litigated matters.





Mark J. Phillips
Shareholder
Lewitt Hackman
Email: mphillips@lewitthackman.com
Mark is a certified specialist in estate planning, trust & probate law by the State Bar of California.

California law allows litigants to appear individually on their own behalf, in propria persona or “in pro per.” However, individuals cannot represent others in court unless they are licensed attorneys. The difference between these two capacities can become blurred in probate and conservatorship matters when it is unclear on whose behalf a fiduciary appears. The recent case of Sanchez v. Peralta (filed 8/9/23, Sixth Appellate District) brin...
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