COMMITTEE ON CODES OF CONDUCT
ADVISORY OPINION NO. 96

Service as Fiduciary of an Estate or Trust.

The Committee frequently is asked to give advice regarding whether a judge may serve as a fiduciary of an estate or trust. This opinion will summarize the principles applicable thereto.(1)
Canon 5D provides:

D. Fiduciary Activities. A judge should not serve as the executor, administrator, trustee, guardian, or other fiduciary, except for the estate, trust, or person of a member of the judge's family, and then only if such service will not interfere with the proper performance of judicial duties. "Member of the judge's family" means any relative of a judge by blood, adoption, or marriage or any other person treated by a judge as a member of the judge's family.

As a family fiduciary a judge is subjected to the following restrictions:

(1) The judge should not serve if it is likely that as a fiduciary the judge will be engaged in proceedings that would ordinarily come before the judge or if the estate, trust or ward becomes involved in adversary proceedings in the court on which the judge serves or one under its appellate jurisdiction.

(2) While acting as a fiduciary a judge is subject to the same restrictions on financial activities that apply to the judge in his or her personal capacity.
This canon places substantial restrictions on the ability of judges to serve as a trustee or other fiduciary.(2) Judges may not serve as fiduciaries in non-family situations, even where the amount of work involved is minimal. See Advisory Opinion No. 33 (judge should not serve as co-trustee of pension trust). Although judges are permitted to serve as fiduciaries in family situations,

1. This subject was discussed in Advisory Opinions No. 5 and 16, which have been withdrawn.

2. An explanation of the reasons for these restrictions appears in Thode, Reporter's Notes to Code of Judicial Conduct 87-88 (ABA 1973): when a judge appears as a fiduciary the judge may appear to have an advantage over other litigants or lawyers in a proceeding before a fellow judge; this risk justifies limitations on judges' fiduciary activities absent important countervailing considerations, such as family relationship.

Canon 5D(1) advises against doing so if it would interfere with judicial duties or lead to litigation in the judge's court. Canon 5D contains a relatively expansive definition of family member for these purposes. Residence in the judge's household is not required in order for a person to be considered a member of the judge's family, nor must the person be related by blood, adoption, or marriage. However, more is required than mere residence in the household, longstanding affective ties, or an underlying business relationship. Persons must be treated by the judge as a member of the judge's family in order to be considered family members under this canon.

Newly appointed judges who are serving as fiduciaries when they are appointed should refer to the Applicable Date of Compliance provision set out at the end of the Code of Conduct. The compliance provision advises newly appointed judges to "arrange their affairs as soon as reasonably possible to comply with" the Code of Conduct and to do so in any event within one year following appointment. This means that judges should discontinue their service as nonfamily fiduciaries within a year of their appointment. However, the compliance provision provides for an exception to this advice in the following circumstances:

Under Canon 3C(1)(c), judges are required to recuse in any proceeding in which they know they hold a financial interest in a party, whether the interest is held individually or as a fiduciary. Canon 5D(2) confirms that judges acting as fiduciaries are subject to the same restrictions on financial activities that apply in their personal capacity. A judge who serves as a trustee is deemed to have a financial interest in all assets held by the trust and, therefore, is required to recuse in cases where a corporation whose securities are held by the trust is a party. In this event, the remittal provisions of Canon 3D are not available; in other words, the parties may not waive the judge's disqualification and permit the judge to serve. Judges have an obligation under Canon 3C(2) to keep informed about their fiduciary financial interests so they can recuse themselves when necessary.

Canon 5C(4) also bears on a judge's service as a trustee; it advises that judges "should manage investments and other financial interests to minimize the number of cases in which the judge is disqualified." A judge who serves as a trustee may be able to divest the trust of holdings whose retention would require the judge to recuse frequently, assuming this can be done consistently with the judge's fiduciary obligations as trustee. If not, and if the trust assets trigger frequent disqualifications that prove disruptive to the court, the judge should consider whether he or she may properly continue to serve or whether resignation would be appropriate, consistent with the judge's obligations under Canon 5C(4).

A judge who is permitted to serve as a trustee for a family trust may accept compensation for such service if the source of the compensation does not give the appearance of influencing the judge in the judge's judicial duties or otherwise give the appearance of impropriety, if the compensation does not exceed a reasonable amount, and if it does not exceed what a person who is not a judge would receive for the same activity. See Code of Conduct for United States Judges, Canon 6. Such compensation must be reported on the judge's annual Financial Disclosure Form and is subject to the limitations on outside earned income set forth in the Ethics Reform Act of 1989 and the regulations issued thereunder by the Judicial Conference. See Judicial Conference Regulations Concerning Outside Earned Income, Honoraria, and Outside Employment § 3 and Commentary ¶ 10. Although these regulations also prohibit judges from serving as a fiduciary for compensation, that prohibition does not apply to service "as an executor or trustee of a family estate or trust as permitted by the Codes of Conduct where the [judge] . . . does no more than provide the service that would be provided by a lay person in the same capacity." See id. However, even in the limited circumstances where judges may continue to serve as a nonfamily trustee, as noted above, judges should not accept compensation for service as a nonfamily trustee.

January 15, 1999