Time limits on outstanding checks?

I received a claim against the estate for a check that was written to a private individual (perhaps as a gift/no service rendered) by the deceased 10 months prior to the date of death. Another 10 months passed (9 months after the estate was opened) and a claim for the check, which still had not been deposited by the recipient has been filed against the estate. Most of the assets of the estate have been distributed; the claim exceeds the remaining assets.

Does the claimant have a legitimate claim against the estate, even though there was never an attempt to deposit the check?