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Say there's a lich who made a pact with an evil entity for the secrets of lichdom, but he was at the moment unsure of the ramifications of such a decision. He befriended the adventuring party prior to his becoming a lich, and they would know him well (hopefully). When they encounter him, he would ask to be released from this dark pact. By then, he would not have been dead for the over 200 years.

So, the main question really is as follows: Would the pact or phylactery constitute the lich's soul as not free with respect to the fact a soul has to be free and willing within the text of True Resurrection?

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A dead lich may be resurrected if its phylactery is also destroyed

When discussing whether true resurrection can raise a lich, there are 3 distinct cases that must be considered.

Undead/Not dead lich - cannot be targeted by true resurrection

You touch a creature that has been dead for no longer than 200 years and that died for any reason except old age. ... the creature is restored to life ...

True resurrection requires a dead creature to be the target of the touch. A lich is an undead creature, but it is not dead. Jeremy Crawford confirms this:

An undead creature is not dead.

It is thus not a valid target for true resurrection.

So, using true resurrection will only work on a lich that has been killed. The effectiveness of the spell in this case will be determined by the state of the lich's phylactery.

Dead lich, phylactery intact - cannot be resurrected

If you kill the lich (before destroying the phylactery) then use true resurrectionit likely will not be able to come back to life because:

A lich is created by an arcane ritual that traps the wizard's soul within a phylactery... where it forever remains.

A soul that is trapped forever in a container is not "free and willing" which means that the soul does not meet this condition of true resurrection:

If the creature's soul is free and willing the creature is restored to life...

Since it does not meet that condition, the lich cannot be restored to life by true resurrection while its phylactery remains intact and active.

Dead lich, phylactery destroyed - can be resurrected as non-undead creature

If you kill the lich (after destroying the phylactery) then use true resurrection it will return to life as as the creature it originally was.

Per the description of true resurrection (after errata):

If the creature was undead, it is restored to its non-undead form

Assuming that the soul is now willing after being freed from the phylactery this means that the (former) lich can now be resurrected to its non-undead form.

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  • \$\begingroup\$ The conversation attached to this answer has been moved to chat. \$\endgroup\$
    – doppelgreener
    Commented Apr 16, 2018 at 14:30
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    \$\begingroup\$ Does the "dead no more than 200 years" bit start at when they died first (pre-undead) or when you kill the lich? E.g. if a wizard died in the year 100, was immediately raised as a lich, and then is killed by the players in the year 400, can they still resurrect him until the year 601 or are they out of luck? \$\endgroup\$
    – TylerH
    Commented Apr 16, 2018 at 15:15
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    \$\begingroup\$ @TylerH: Good question. I would strongly argue that time is counted from the time you killed the lich. Since a lich isn't dead it certainly shouldn't count towards towards dead time. So this would just mean that the dead clock starts every time you die and gets reset every time you un-die. All the time in between does not matter. \$\endgroup\$
    – Rubiksmoose
    Commented Apr 16, 2018 at 15:19
  • \$\begingroup\$ @Rubiksmoose Interesting; so if you have a party member who can cast lich-creating spells, you could combine it with a true resurrection spell to theoretically "True Resurrect" someone who has been dead for millennia! \$\endgroup\$
    – TylerH
    Commented Apr 16, 2018 at 15:29
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    \$\begingroup\$ @TylerH: Well, for better or for worse, there are no lich-creating spells in 5e. But yeah resurrecting a lich would mean that you are returning the mortal form of a creature that may not have been seen for a very long time. Though I must stress, according to the rules, they have not been dead for that time. \$\endgroup\$
    – Rubiksmoose
    Commented Apr 16, 2018 at 15:32
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The phylactery would probably restrict the use of resurrection magic on the Lich.

The Monster Manual has the following to say about the Lich and their phylactery:

A lich is created by an arcane ritual that traps the wizard's soul within a phylactery. Doing so binds the soul to the mortal world, preventing it from travelling to the Outer Planes after death.

And also, after completing the ritual to transform into a lich:

The wizard falls dead, then rises as a lich as its soul is drawn into the phylactery, where it forever remains.

Specifically, the soul is described as being "trapped" in the phylactery. I would definitely read this to mean that the soul is not free, even if the lich personally is willing to be resurrected, and so the criteria for successful resolution of the spell are not met.

However, if the phylactery and subsequently the lich's body was destroyed, True Resurrection would be able to restore the lich to mortal life. As per errata to True Resurrection:

If the creature was undead, it is restored to its non-undead form.

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  • \$\begingroup\$ Why would it return the lich to mortal life and not back to its undead form? \$\endgroup\$
    – David Coffron
    Commented Apr 15, 2018 at 22:26
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    \$\begingroup\$ @DavidCoffron because as per errata, "If the creature was undead, it is restored to its non-undead form." \$\endgroup\$
    – Carcer
    Commented Apr 15, 2018 at 22:30

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