Can an estate trustee appointed during litigation still sell estate property while the estate is being contested?

Generally, only in a limited way. An estate trustee during litigation is a special, interim appointment made specifically because there's a genuine dispute over the estate, such as a will challenge or a fight over who should be the permanent trustee, and their role is primarily to preserve and protect the estate's assets while that dispute is resolved, not to administer the estate with the same broad discretion an ordinary, uncontested trustee would have.

Because of that limited purpose, an estate trustee during litigation typically needs specific authorization from the court, whether through the terms of their appointment or a separate order, before selling significant assets like real estate, rather than relying on a general power of sale the way a regular estate trustee with an uncontested Certificate of Appointment could. That said, a sale can still be appropriate and permitted during this period, particularly where the property is depreciating, costly to maintain, or a sale is genuinely in everyone's interest regardless of how the underlying dispute is eventually resolved. Anyone acting as an estate trustee during litigation who is considering a real estate sale should confirm the scope of their specific court-ordered authority before proceeding, rather than assuming it matches an ordinary trustee's powers.