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Why a Creditor Cannot Just Sue the Trust

The heading says limitations. There is no deadline anywhere in it.

Section 736.1014 sends a dead settlor’s creditors into the probate estate, and expressly preserves the claims that do not belong there.

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Quick Overview

Creditor actions against certain trusts

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Below, we walk through the 4 issues that decide whether this is the right move for you. Jump to any one.

  1. The channelling rule Present the claim against the estate, not the trust.
  2. The test Whether the claim depends on the settlor’s individual liability.
  3. What is preserved Claims not dependent on that are expressly allowed.
  4. Secured creditors Mortgages and liens are untouched.

That’s the quick version. The details below are what decide your situation, and where the costly mistakes hide.

The heading is misleading, so start with the text

The catchline says limitations on actions. That leads people to expect a period of years. There is no deadline in this section at all. What it does is decide where a claim must be brought, not when.

After the death of a settlor, no creditor of the settlor may bring, maintain, or continue any direct action against a trust described in s. 733.707(3), the trustee of the trust, or any beneficiary of the trust that is dependent on the individual liability of the settlor.

Section 736.1014(1), Florida Statutes.

The claim does not disappear. The same subsection says where it goes. It must be presented and enforced against the settlor’s estate as provided in part VII of chapter 733, and the personal representative may then obtain payment from the trustee.

So the machinery is a loop. Creditor to estate, estate to trust. Our page on section 736.05053 covers the second half of that, which is the trustee’s duty to pay the settlor’s estate obligations and the order in which things get paid.

Why the law is built this way

A revocable trust is a will substitute. During life the settlor can take everything back, so the property is realistically theirs. On death, the trust holds assets that would otherwise have gone through probate.

If creditors could sue the trust directly, the probate claims process would be optional. The fast creditor would reach the trustee first and be paid in full, and the careful one who filed properly would find nothing left. The section exists to stop that race, by making the estate the single place claims are sorted and ranked.

The phrase that decides which route you are on

Everything turns on dependent on the individual liability of the settlor, and it appears in both subsections. Subsection (1) channels claims that are. Subsection (2) preserves claims that are not.

This section does not preclude a direct action against a trust described in s. 733.707(3), the trustee of the trust, or a beneficiary of the trust that is not dependent on the individual liability of the settlor.

Section 736.1014(2), Florida Statutes.

The distinction is between claims you had against the person and claims you have against the trust or the people running it.

A debt the settlor owed you personally is the first kind. That claim depends entirely on their liability, and it goes to the estate. But a claim that the trustee breached a duty to you, or that a beneficiary received something improperly, does not depend on the settlor having been liable at all. Those are preserved, and this section says nothing about them.

A beneficiary suing over trust administration is therefore untouched by this provision, whatever else may bar the claim.

The limits on the section

Only certain trusts. The section applies to a trust described in section 733.707(3), which is the settlor’s revocable trust. It is not a general rule for every trust a settlor ever created. An irrevocable trust funded years before death is outside it, and creditor access there is governed by section 736.0505 and the fraudulent transfer law.

Secured creditors are untouched. Subsection (3) preserves the lien of any duly recorded mortgage or security interest, the lien of a person in possession of personal property, and the right to foreclose and enforce it. A mortgagee does not have to go near probate. That is orthodox. The channelling rule is about unsecured claims competing for a limited pot, and a secured creditor is not competing.

No Florida court has cited this section

A search returns no citing documents anywhere we searched.

The likely reason is that the fights happen one step along, over whether a claim was properly presented in the probate estate and whether the trustee must pay it. Those are chapter 733 and section 736.05053 questions, and there is authority on them.

What remains untested here is the phrase the whole section turns on. No Florida decision tells you when a claim is dependent on the individual liability of the settlor, and the hard cases are easy to imagine, among them a contract the settlor signed as trustee, a tort committed while managing trust property, and a guarantee of a trust obligation. We report the nil result as our own review rather than as a certainty.

A creditor is chasing the trust

The first question is whether the claim depends on the settlor being personally liable.

Frequently Asked Questions

Can a creditor of someone who died sue their revocable trust?

Not for a claim that depends on the settlor's individual liability. Section 736.1014 provides that after the settlor's death no creditor of the settlor may bring, maintain or continue any such direct action against the trust, the trustee, or a beneficiary.

Where does the claim go instead?

Against the settlor's estate, presented and enforced as provided in part VII of chapter 733. The personal representative can then obtain payment from the trustee under sections 733.607(2), 733.707(3) and 736.05053.

Does the section stop every claim against the trust?

No, and subsection (2) says so expressly. A direct action against the trust, the trustee or a beneficiary that is not dependent on the individual liability of the settlor is not precluded.

Does it apply to every trust?

No. It applies to a trust described in section 733.707(3), which is the settlor's revocable trust. An irrevocable trust the settlor created years earlier is a different question.

What about a mortgage on trust property?

Unaffected. Subsection (3) preserves the lien of any duly recorded mortgage or security interest, the lien of a person in possession of personal property, and the right to foreclose or enforce it.

Is there a deadline in this section?

No, despite the heading. The deadlines that matter come from the probate claims process in part VII of chapter 733, which is where the section sends you.

Common Situations

You are owed money by someone who died. If they had a revocable trust, file in the probate estate.

The estate has nothing and the trust has everything. The personal representative can reach the trust. That is the design.

You hold a mortgage on trust property. Subsection (3) leaves your rights alone.

Your claim is against the trustee, not the settlor. Subsection (2) preserves it.

Sources of Law


Updated on August 16, 2026. Reviewed by Kevin D. Klagge, Esq., Fla. Bar No. 99502. Attorney Kevin Klagge represents families, businesses, and international clients in estate and tax planning, business structuring, and international law, with a focus on Florida legal tools. He litigates estate and business issues in court. General information about Florida law and published court decisions, not legal advice, and no attorney-client relationship is created. Reading this page does not make us your lawyers. Please do not send confidential details until we have connected.

Talk through a creditor claim

Bring the claim and the trust. Which route it takes is decided by what the claim depends on.