John R. Armstrong v. Terry L. Armstrong
170 So.3d 510, 2015 Miss. LEXIS 378 (2015)
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Rule of Law:
Mississippi's Slayer Statute, which prohibits a person who 'wilfully' causes the death of another from inheriting from the victim, does not apply if the killer was insane at the time of the killing, as an insane person cannot form the requisite willful intent. A civil hearing is required to determine the killer's mental state at the time of the act, regardless of the status of any criminal proceedings.
Facts:
- John R. Armstrong had a long history of serious mental illness, including a diagnosis of paranoid schizophrenia, and had been receiving treatment since 1989.
- On August 7, 2010, after John was seen acting erratically, his mother, Joan Armstrong, picked him up and brought him to her condominium.
- Worried that his mother was leaving him, John retrieved a crochet-covered brick and repeatedly hit her over the head with it.
- John then moved his mother's body to the bathroom and stabbed her multiple times.
- When law enforcement arrived, John told them he was preparing his mother's body for burial by 'bleeding her.'
- John admitted to law enforcement officers that he had killed his mother.
- Joan Armstrong's will stipulated that her estate be divided equally among her five children, including John.
Procedural Posture:
- John Armstrong was indicted for the murder of his mother, Joan Armstrong.
- The Circuit Court ordered a mental evaluation and subsequently found John not competent to stand trial, committing him to the state hospital.
- Terry Armstrong, John's brother and the executor of Joan's estate, filed a petition in the Chancery Court of Jackson County to probate their mother's will.
- Terry then filed a Motion to Declare Devise Void as to John, arguing the Slayer Statute barred John from inheriting.
- The Chancery Court appointed a guardian ad litem to represent John's interests.
- The chancellor of the Chancery Court granted the motion, finding that John wilfully caused Joan's death and was therefore barred from inheriting under the Slayer Statute.
- John, through his guardian ad litem, appealed the chancellor's decision to the Mississippi Supreme Court.
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Issue:
Does Mississippi's Slayer Statute, which prohibits a person who 'wilfully' causes the death of another from inheriting from the victim, apply to a killer who is severely mentally ill and may have been insane at the time of the killing?
Opinions:
Majority - Randolph, Presiding Justice
No. The Mississippi Slayer Statute does not apply to a killer who was insane at the time of the killing because an insane person cannot form the requisite 'willful' intent required by the statute. The court's analysis centered on the statutory term 'wilfully,' interpreting it to be synonymous with 'knowingly' and 'intentionally.' Following the majority rule from other jurisdictions, the court held that an insane person lacks the capacity to act willfully. The determination of a killer's competency to stand trial in a criminal proceeding is a separate issue from their sanity at the time of the killing. Therefore, a civil hearing must be conducted to specifically determine the killer's mental state at the time of the act to decide if the Slayer Statute applies. The lower court erred by voiding the devise without such a hearing.
Analysis:
This case of first impression establishes the legal standard in Mississippi for applying the Slayer Statute to individuals with severe mental illness. The decision clarifies that 'wilfully' under the statute requires a specific intent that a legally insane person cannot form, effectively creating an insanity exception to the statute's application. It bifurcates the civil probate proceeding from any criminal prosecution, requiring an independent civil determination of the killer's sanity at the time of the act. This ruling sets a precedent that will guide Mississippi courts in future cases involving inheritance claims by killers whose mental capacity is in question.
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