Estate of Whitley, 50 A.3d 203

Decedent died in 2008; will named Executor and distributed to four children.
Executor filed first and final accounting; Appellants objected alleging undue influence.
Objections to accounting were treated as challenges to will validity; court dismissed them as improper.
Appellants sought to challenge will validity via accounting objections, arguing exclusive probate appeal not required.
Orphans’ Court adjudication confirmed accounting and later awarded Executor additional professional fees; Appellants appealed.
Court held objections were collateral attacks on the will and lacked jurisdiction; fees award upheld; appeal from probate was required.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether objections to the accounting suitably challenge will validity	Hulme et al. argued accounting objections suffice to contest will.	Executor argued direct probate appeal is exclusive path; objections collateral attack.	Objections were improper collateral attack; no jurisdiction without probate appeal.
Whether the fee award to defend the will contest was proper	Fees were improper since the contest was improperly initiated.	Fees reasonable and incurred defending an improper will contest; properly paid by estate.	Fees award affirmed; appellants waived challenge by failing to object to amount.

In re Hickman’s Estate, 308 Pa. 230 (Pa. 1932) (will validity review limited to appeal from probate)
In re Miller’s Estate, 166 Pa. 97 (Pa. 1895) (only appeal from probate brings will validity within Orphans’ Court)
Bunce v. Galbrath, 268 Pa. 389 (Pa. 1920) (collateral attacks on will not permitted)
Zeigler v. Storey, 220 Pa. 471 (Pa. 1908) (register's actions cannot be attacked in collateral proceeding)