When will an administrator or executor of an estate proceed pro se?

We have previously held that "an administrator or executor of an estate may not proceed pro se when the estate has beneficiaries or creditors other than the litigant." Pridgen, 113 F.3d at 393. Where there are other beneficiaries, "an action cannot be described as the litigant's own, because the personal interests of the estate, other survivors, and possible creditors... will be affected by the outcome of the proceedings." Iannaccone v. Law, 142 F.3d 553, 559 (2d Cir.1998). But we have reserved the question of whether an administrator or executor of an estate may proceed pro se when the estate has no creditors and no beneficiaries other than the administrator. See Pridgen, 113 F.3d at 393.⁴

[603 F.3d 21]