Which of the following is NOT included as a type of recovery for a trustee's breach of trust?

The correct answer highlights that legal fees incurred by the beneficiary are not typically considered a type of recovery directly for a trustee’s breach of trust. When a trustee breaches their fiduciary duty, the primary remedies focus on restoring the trust’s value, recovering profits gained by the trustee from the breach, or other forms of relief that the court deems appropriate.

Restoring the trust to its correct value ensures that beneficiaries are made whole, as if the breach had not occurred. Recovering trustee profits directly addresses any financial gains made by the trustee due to their misconduct, which is aligned with the principle of disgorgement. Additionally, courts can grant other forms of relief based on the specifics of the case, depending on the damages suffered by the beneficiaries.

In contrast, legal fees incurred by beneficiaries are often viewed as separate from the direct recovery for the breach itself. While beneficiaries may seek to recover these fees in a broader context of litigation, they are not categorized under the direct types of recovery established for the breach of trust. This distinction is crucial for understanding the boundaries and specific remedies available in trust law.