The probate court is a court of limited jurisdiction and may exercise its powers as conferred by statute. Despite any such limitations, the probate court may dispose fully of any matter that is properly before it. A trust beneficiary’s failure to satisfy that he has suffered an injury precludes the beneficiary from establishing common law standing. Without common law standing, a trust beneficiary must strictly adhere to R.C. 2107.46 to establish statutory standing. Possessing neither form of standing, a beneficiary is precluded from asserting a cause of action against third parties on behalf of the trust. This article demonstrates the delay and costs to a trust caused by a beneficiary asserting claims for which the beneficiary has no right under Ohio law to maintain as recently decided by the 8th District Court of Appeals in Campbell v. Donald A. Campbell 2001 Trust.

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