Bad Faith Comes at Full Price: Moramarco v. Nowakoski and the Teeth of Probate Code Section 859

Bad Faith   Fiduciary Duty   Probate   Probate Code Section 859   Probate Litigation   Trust Litigation   Trustee Misconduct   Trustees  

July 22, 2026


EXTERNAL URL: https://www.trustontrial.com/2026/07/bad-faith-comes-at-full-price-moramarco-v-nowakoski-and-the-teeth-of-probate-code-section-859/

AUTHORS: Downey Brand

Meet Edward Nowakoski. Once a practicing attorney and trustee, he is now disbarred, on criminal probation, and has paid more than $542,000 in restitution. The final cherry