In re Estate of Lucas — Ohio appeals court upholds removal of estate administrator

Case
In the Matter of the Estate of Randall Lucas, Deceased
Court
Ohio Court of Appeals, Second Appellate District, Montgomery County
Judge
Robert G. Hanseman, Judge; Lewis, P.J.; Huffman, J.
Date Decided
October 2, 2026
Docket No.
C.A. No. 30812
Topics
Probate; Estate administration; Fiduciary removal; Guardian ad litem
Source
Read the full opinion

Background

Randall Lucas died intestate in 2021, leaving a complex estate that included rental real estate, vehicles, and two LLCs. Thirteen heirs were identified, including six minors represented by guardians ad litem. The probate court appointed attorney Worrell A. Reid as administrator in June 2022.

In October 2025, Maxwell B. Newsome, guardian ad litem for a minor heir, sought Reid’s removal. After a hearing, the probate court removed Reid, finding that he had filed the estate inventory and accounts late, managed estate real estate and LLC operations without required authority, sought to transfer estate real estate to one heir, and failed to obtain necessary LLC appraisals.

The Court’s Holding

The Second District affirmed. It held that the probate court did not abuse its discretion in removing Reid under R.C. 2109.24, which permits removal of a fiduciary for failures in estate administration and other cause.

The record supported each basis for removal: Reid filed the inventory and accounts late; managed rental property and continued LLC operations without probate-court authorization or required reporting; attempted to convey property to one heir without adequate proof or protection for the minor heirs’ interests; and failed to obtain appraisals that accounted for the LLCs’ liabilities. The court also held that excluding Newsome’s testimony was not an abuse of discretion because Reid sought attorney work-product information, the proposed testimony was immaterial, and Reid was not prejudiced.

Key Takeaways

  • Probate courts have broad discretion to remove an estate administrator under R.C. 2109.24.
  • An administrator must obtain required authority before managing estate real property or continuing a decedent’s businesses.
  • A guardian ad litem who files a removal motion is not necessarily a witness subject to examination about litigation strategy.

Why It Matters

The decision underscores that complexity in an estate does not excuse untimely accounting, unauthorized management, or inadequate protection of all heirs’ interests. Administrators must comply with probate-court orders and statutory reporting requirements, particularly when estate assets include businesses, rental property, and minor beneficiaries.

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