A Florida daughter lost control of her late mother’s estate and three family trusts after representing them in court without a lawyer; a November 12 appeals court upheld all four removals despite her objections

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Managing a deceased parent’s estate and family trusts can involve complex legal responsibilities, particularly when disagreements arise among beneficiaries. A Florida daughter who continued representing her late mother’s estate and three family trusts in court without a lawyer has now lost all four positions after an appeals court upheld her removal, finding that her actions violated established legal requirements.In a November 12, 2026, decision, the Florida Third District Court of Appeal affirmed four removal orders against Kerrin Friedman. The rulings removed her as personal representative of her mother Bonny L Wax’s estate and as trustee of three family trusts. In Kerrin Friedman v. In Re: Estate of Bonny L Wax, available on Justia, the appeals court rejected her arguments that the probate court lacked authority to remove her and had denied her due process.

Daughter continued representing estate without a lawyer

The dispute involved four separate probate and trust proceedings in Miami-Dade County. Friedman was appointed personal representative of her late mother’s estate and also served as trustee of three trusts connected to her siblings: the Bobbi Ring Trust, the Adam Wax Trust and the Credit Shelter Trust. However, her decision to represent these legal entities herself became a central issue in the proceedings.On April 17, 2025, the probate court ordered Friedman to obtain a lawyer within 30 days to represent her in the estate case. The requirement followed Florida Probate Rule 5.030(a), which generally requires a personal representative to be represented by a Florida attorney unless that person is the estate’s sole interested person. Instead of complying, Friedman continued representing herself in the estate proceedings. She also appeared without a lawyer in the appeals court and federal court.

Court barred her from representing family trusts

The legal restrictions extended to her role as trustee. On July 3, 2025, the probate court issued an order in the Adam Wax Trust case prohibiting Friedman from representing the trust herself. Under Florida law, a trustee who is not a licensed attorney cannot represent a trust’s interests in litigation because doing so constitutes the unauthorised practice of law.Despite the order, Friedman continued filing documents on behalf of the Adam Wax Trust without legal representation. She also began representing herself as trustee in the subsequently filed Bobbi Ring Trust and Credit Shelter Trust proceedings. Meanwhile, the other parties involved in the trust cases sought her removal, raising several allegations of misconduct in their motions.

Probate court ordered removal from all four positions

At a September 16, 2025, hearing, the probate court announced that it would remove Friedman as personal representative of her mother’s estate and as trustee of all three family trusts. The court cited her continued unauthorised self-representation, among other grounds. It subsequently entered formal removal orders in all four proceedings.Friedman challenged the decisions, arguing that the probate court lacked statutory authority to remove her from the positions. She also claimed that the September hearing violated her right to due process.

Appeals court rejects daughter’s objections

The Florida Third District Court of Appeal rejected both arguments. On the due-process issue, the judges noted that Friedman had received notice of the September 16 hearing and had an opportunity to present her position. The court therefore found no basis to conclude that she had been denied a fair opportunity to be heard. The appeals court also explained that Florida law expressly authorises probate courts to remove personal representatives in certain circumstances.Under Florida Probate Rule 5.440(a), a probate court may remove a personal representative on its own initiative. Section 733.504(3) of the Florida Statutes also permits removal when a personal representative violates a court order. The judges found that Friedman had violated the April 17 order requiring her to retain legal counsel.Regarding the three trusts, the court relied on Section 736.0706 of the Florida Statutes, which allows a court to remove a trustee under specified circumstances, including when the trustee has committed a serious breach of trust or other grounds justify removal. The judges explained that a non-lawyer trustee cannot represent a trust in litigation. Friedman’s continued attempts to do so, despite the court’s July 3 order, provided sufficient grounds for her removal.

All four removal orders upheld

The appeals court clarified that it did not need to decide whether the separate allegations of misconduct raised against Friedman were justified. Her unauthorised self-representation alone provided sufficient grounds for the probate court’s decisions. It ultimately affirmed all four removal orders, leaving Friedman without control over her mother’s estate or the three family trusts.The November 12 ruling addresses her authority to serve in these legal roles and does not determine the merits of the separate misconduct allegations raised by the other parties. The opinion is not final until any timely motion for rehearing has been resolved.