Pritchett v. Henry
287 S.W.2d 546, 1955 Tex. App. LEXIS 2364 (1955)
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Rule of Law:
A person who willfully and unlawfully kills another holds any property acquired from the victim, either by will or by inheritance, in a constructive trust for the benefit of the victim's other heirs. This equitable remedy prevents the killer from being unjustly enriched by their crime.
Facts:
- Howard and Clyda Pritchett were the parents of Melba Henry.
- Melba Henry was married to Percy B. Henry.
- On or about January 8, 1955, Percy B. Henry allegedly shot and unlawfully killed his wife, Melba Henry.
- At the time of her death, Melba Henry had a will that named her husband, Percy B. Henry, as the beneficiary of her estate.
- As her surviving spouse with no children, Percy B. Henry was also Melba Henry's legal heir under Texas intestacy statutes.
- Melba Henry also had several life insurance policies naming Percy B. Henry as the beneficiary.
- The Pritchetts were Melba Henry's next heirs at law after Percy B. Henry.
Procedural Posture:
- Howard and Clyda Pritchett (appellants) sued Percy B. Henry (appellee) in a Texas district court (trial court).
- Henry filed a plea in abatement, arguing that the Pritchetts' petition failed to state a valid cause of action for forfeiting his inheritance.
- The trial court sustained Henry's plea and dismissed the Pritchetts' cause of action concerning the will and inheritance.
- The related cause of action regarding life insurance proceeds was severed by agreement and was not part of the appeal.
- The Pritchetts, as appellants, appealed the trial court's dismissal to the Court of Civil Appeals.
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Issue:
Does a person who willfully and unlawfully kills another forfeit the right to take and keep property as an heir or legatee of the victim, by having a court impose a constructive trust on the property for the benefit of the victim's other heirs?
Opinions:
Majority - R. L. Murray, Chief Justice
Yes. A person who willfully and unlawfully kills another cannot retain and enjoy property inherited from the victim. Although legal title to the property may pass to the killer under the statutes of wills or descent, equity will impress a constructive trust upon the property for the benefit of the victim's heirs, other than the killer, to prevent unjust enrichment. The court rejected the older precedent of Hill v. Noland, which held that inheritance statutes were absolute and contained no exceptions for murder. Instead, the court adopted the 'more modern view' suggested in cases like Pope v. Garrett and advocated by legal scholars. This view holds that imposing a constructive trust is not an impermissible judicial amendment to the statutes, but rather an application of the well-settled equitable principle that prevents a person from profiting from their own wrongdoing. The statute is left untouched—legal title passes as written—but equity then deals with the holder of that title to prevent a fraudulent or unconscionable result.
Analysis:
This decision aligned Texas law with the majority of American jurisdictions by adopting the constructive trust as a remedy against 'slayer' beneficiaries. It effectively set aside the outdated, strict statutory interpretation of Hill v. Noland, which courts had followed for decades. By doing so, the court affirmed its power to use equity to achieve justice where rigid application of a statute would lead to an unconscionable result, specifically preventing a murderer from being rewarded for their crime. This case solidifies the principle that statutes of descent and distribution do not operate in a vacuum and are subject to fundamental equitable doctrines against unjust enrichment.
