When bringing an action for breach of fiduciary duty for failure to provide a Florida trust accounting, timeliness of the action is key. If the beneficiary does not timely file, then they will not be entitled to an accounting. There is a four-year statute of limitations for bringing this type of claim; however, there is an exception—if the beneficiary receives a receipt of limitation notice, then a six-month limitation is triggered, as discussed in Woodward v. Woodward. In Corya v. Sanders, however, based on the facts of the case, the court concluded that beneficiaries who had not received accountings or limitations notice could not request accountings going back over four years.
See Anya Van Veen, Florida Trust Accountings: 4 Years or 6 Months to Sue? Woodward v. Corya, Florida Probate Lawyers, August 4, 2016.
