Riggs v. . Palmer
23 Abb. N. Cas. 452, 22 N.E. 188, 115 N.Y. 506 (1889)
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Rule of Law:
A beneficiary of a will who murders the testator is not entitled to inherit under the will, as the common law maxim that no one shall be permitted to profit from their own wrong will be applied to prevent an unjust result, even if not explicitly prescribed by statute.
Facts:
- Francis B. Palmer executed a will, leaving small legacies to his daughters, Mrs. Riggs and Mrs. Preston, and the remainder of his estate to his grandson, Elmer E. Palmer.
- At the time the will was made, Elmer was sixteen years old and lived with his grandfather, Francis.
- Elmer knew he was the principal beneficiary under his grandfather's will.
- Francis Palmer had remarried and had expressed an intention to revoke the provisions in his will that favored Elmer.
- To prevent his grandfather from changing the will and to gain immediate possession of the estate, Elmer murdered Francis Palmer by poisoning him in 1882.
Procedural Posture:
- The plaintiffs, Mrs. Riggs and Mrs. Preston, brought an action against the defendant, Elmer E. Palmer, in a court of first instance to have the provisions of the will in Elmer's favor declared void.
- The case was decided by a referee, who found in favor of the defendant, Elmer Palmer.
- The plaintiffs (appellants) appealed to the General Term of the Supreme Court, an intermediate appellate court.
- The General Term affirmed the judgment of the trial court, siding with the defendant-appellee, Elmer Palmer.
- The plaintiffs (appellants) then appealed to the New York Court of Appeals, the state's highest court.
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Issue:
Does a beneficiary who murders the testator forfeit their right to inherit under the will, even if the statutes governing wills do not expressly prohibit it?
Opinions:
Majority - Earl, J.
Yes, a beneficiary who murders the testator forfeits their right to inherit. While a literal interpretation of the statutes governing wills would grant the property to the murderer, courts must interpret statutes to fulfill the legislature's intent and avoid absurd results. It is inconceivable that lawmakers intended for a statute to operate in favor of a beneficiary who murders the testator to accelerate their inheritance. The court applied the fundamental common law maxim that no one shall be permitted to profit from his own wrong, fraud, or crime. This principle controls the operation of all laws, including statutes of wills, and prevents the murderer from acquiring property through his crime, not as an additional punishment, but to prevent him from reaping a reward for it.
Dissenting - Gray, J.
No, a beneficiary does not forfeit their right to inherit because the court is bound by the rigid rules of law established by the legislature. The creation, alteration, and revocation of wills are governed entirely by statute, which provides specific methods for these acts and leaves no room for judicial intervention on equitable grounds. The will was valid and not revoked in any manner prescribed by law, so it must be enforced as written. Denying the inheritance would impose an additional punishment on the defendant beyond his criminal sentence, which the courts have no power to do. The court's role is not to create a system of 'remedial justice' where the legislature has been silent, but to enforce the statutes as they exist.
Analysis:
This landmark case established the 'slayer rule' in American jurisprudence, which prevents a murderer from inheriting from their victim. The decision is a classic example of purposive or equitable statutory interpretation, where the court looked beyond the literal text of a statute to avoid an absurd and unjust outcome. It affirmed that fundamental common law maxims can override the plain meaning of a statute when a literal reading would violate public policy. This case represents a foundational conflict between legal formalism (the dissent) and a more justice-oriented, equitable approach to judicial interpretation (the majority).
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