Voluntary personal representative seeking formal personal representative appointment in Massachusetts

The Massachusetts Supreme Judicial Court has ruled that the position of
voluntary personal representative under G. L. c. 190B, § 3-1201, is an appointment, falling within the exception to the three-year time limit in §3-108 for “appointment proceedings relating to an estate in which there has been a prior appointment” and, therefore, the petitioner’s petition for formal appointment was timely.