Attorney's Duty of Loyalty to Beneficiaries
In In re Estate of Shano, 177 Ariz. 550, 556, 869 P.2d 1203, 1209 (App. 1993), we held that, while a personal representative owes a duty of fairness and impartiality to all beneficiaries, the attorney owes a client "a duty of undeviating and single allegiance."
We clarified that holding in In re Estate of Fogleman, 197 Ariz. 252, 257, P11, 3 P.3d 1172, 1177 (App. 2000), in which we noted that the beneficiary is not a client of the personal representative's attorney and, therefore, that no duty of undivided loyalty is owed by the attorney to the beneficiaries.