In the Matter of the Otto Bremer Trust

Summary

The court held that a trustee may be removed for a serious breach of trust consisting of multiple smaller breaches that collectively justify removal. Applying that standard, it concluded that Lipschultz's self-dealing, misuse of grantmaking authority, and failure to disclose his successor cumulatively constituted a serious breach and that the district court did not abuse its discretion in removing him. The court did not reach the alternative statutory ground for removal because the first ground was sufficient.