No proceeding to enforce a claim against the estate of a decedent or his successors may be revived or commenced before the appointment of a personal representative. After the appointment and until distribution, all proceedings and actions to enforce a claim against the estate are governed by the procedure prescribed by this article. After distribution a creditor whose claim has not been barred may recover from the distributees as provided in section 30-24,118 or from a former personal representative individually liable as provided in section 30-24,119 . This section has no application to a proceeding by a secured creditor of the decedent to enforce his right to his security except as to any deficiency judgment which might be sought therein.
Neb. Rev. Stat. § 30-2404
Claims against decedent; necessity of administration
Applied in 10 court decisions — leading case In Re Estate of Reimer (1988)
Most recently applied in Johnson v. Antoniutti (February 2025)
Laws 1974, LB 354, § 82, UPC § 3-104.
How often courts cite this section
Court decisions citing this, by year. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
Official source: Nebraska Legislature. Reproduced from public-domain Nebraska statutes; confirm against the official source for the current text. Not legal advice.