Adams v. Adams — Fourth District affirmed a nonfinal probate order without a written opinion

Case
George James Adams, as Trustee of the Joan F. Adams Declaration of Trust Dated May 20, 1991, as Amended and Restated on October 10, 2007 v. Elizabeth Adams, as Personal Representative of the Estate of Douglas M. Adams
Court
Florida Fourth District Court of Appeal
Judge
Conner; Shepherd; Shaw
Date Decided
September 3, 2026
Docket No.
4D2026-0023
Topics
Probate; Trusts; Nonfinal Appeals
Source
Read the full opinion

Background

George James Adams, acting as trustee of the Joan F. Adams Declaration of Trust, appealed a nonfinal order entered in a Palm Beach County circuit-court probate proceeding involving the Estate of Douglas M. Adams.

Elizabeth Adams, acting as the estate’s personal representative, was the appellee. The Fourth District’s opinion does not describe the challenged order, the parties’ arguments, or the underlying dispute.

The Court’s Holding

The Fourth District Court of Appeal affirmed the nonfinal order.

The court issued a per curiam affirmance without a written explanation. Accordingly, the opinion states no legal rationale and identifies no specific issue resolved beyond leaving the challenged order in place.

Key Takeaways

  • The Fourth District affirmed the circuit court’s nonfinal order.
  • The decision was unanimous, with Judges Conner, Shepherd, and Shaw concurring.
  • Because the court provided no reasoning, the opinion does not establish a stated rule or explain how Florida probate or trust law applied to the dispute.

Why It Matters

The ruling leaves the appealed nonfinal order intact and permits the underlying probate proceeding to continue subject to that order.

Its broader value is limited because the court did not disclose the relevant facts, legal question, or basis for affirmance. The decision was designated nonfinal until disposition of any timely filed motion for rehearing.

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