Master New York’s high court invoked equity to prevent a murderer-beneficiary from inheriting, articulating the foundational slayer rule despite no statute. with this comprehensive case brief.
Riggs v. Palmer is a landmark New York Court of Appeals decision that stands at the intersection of succession law, equity, and statutory interpretation. The case is best known for introducing the equitable slayer rule into American common law: a beneficiary who intentionally kills the testator may not profit from that wrongdoing. Decided in an era before widespread slayer statutes, Riggs demonstrates how courts can deploy equitable principles and purposive reasoning to prevent the law from becoming an instrument of injustice.
For law students, Riggs is a staple in courses on Property (Wills and Trusts) and Legislation/Statutory Interpretation. It illustrates the tension between textualism and purposivism and shows the judiciary’s willingness to infer limits from moral maxims—no one should profit from his own wrong—even when the enabling statute is silent. The majority’s approach, contrasted with a forceful textualist dissent, makes the case a touchstone for debates over the proper role of courts in filling statutory gaps.
Riggs v. Palmer, 115 N.Y. 506, 22 N.E. 188 (N.Y. 1889)
Francis B. Palmer executed a will that left the bulk of his estate to his grandson, Elmer E. Palmer, while making smaller provisions for his two daughters, Mrs. Riggs and Mrs. Preston. After the will was executed, the testator’s relationship with his family evolved, and there was reason to believe he might alter or revoke the will to Elmer’s detriment. To prevent any change, Elmer, then a young man, intentionally poisoned his grandfather, causing his death before any revocation could occur. Palmer’s daughters filed suit in equity to restrain distribution to Elmer and to have him declared ineligible to take under the will, even though New York’s probate statutes at the time contained no explicit provision disqualifying a killer from inheriting. The defendant argued that the statutes governing wills were comprehensive and exclusive, and since the will was duly executed and never revoked, the courts could not add a nonstatutory forfeiture. The plaintiffs contended that allowing Elmer to inherit would violate fundamental equitable principles and public policy.
May a beneficiary who intentionally kills the testator take under a valid, unrevoked will when the governing probate statutes contain no express provision barring such inheritance?
Equity will not permit a person to profit from his own fraud or wrongdoing; statutes are construed in light of their purpose and fundamental moral maxims. Accordingly, where a devisee or legatee intentionally causes the death of the testator to secure a testamentary benefit, the courts will prevent the wrongdoer from taking—typically by treating the wrongdoer as disqualified and imposing a constructive trust in favor of the next rightful takers.
No. The court held that Elmer E. Palmer could not inherit under the will he procured by murdering the testator. The will would not be set aside, but equity would restrain payment to Elmer and treat his interest as held for the benefit of the next entitled beneficiaries.
The majority, per Judge Earl, reasoned that the legislature’s intention, rather than the literal text of the statute of wills, governs. The statute exists to effectuate the testator’s intent and to distribute property in an orderly and just manner. It could not have been within the contemplation of the lawmakers—or the testator—that the law would reward a beneficiary for murdering the testator to prevent revocation. To read the statute to compel such an outcome would defeat its purpose and offend settled equitable maxims that no one should profit by his own wrong and that the law will not permit itself to be used as an instrument of fraud. The court emphasized that applying equity here was not the creation of a new criminal penalty or an unauthorized forfeiture but a remedial adjustment to prevent unjust enrichment. Rather than invalidating the will, the court allowed it to stand while interposing equity to block the wrongdoer’s benefit. The appropriate mechanism was effectively to impose a constructive trust on Elmer’s share for the benefit of those who would take in his absence (the other beneficiaries or heirs). The court also noted that similar principles existed in both common law and civil law traditions. In dissent, Judge Gray warned that the majority was rewriting the probate code by judicial fiat. He argued that the legislature had enumerated the grounds for revocation and disqualification, and the courts were not free to add new ones based on moral sentiment. According to the dissent, criminal law provided the appropriate sanction for murder, and property distribution should follow the statute’s text. The majority rejected this strict textualism, insisting that purposive interpretation and equitable maxims are integral to the law and essential to avoid absurd or immoral results.
Riggs v. Palmer is foundational for both Wills and Trusts and Statutory Interpretation. Substantively, it established the equitable slayer rule in American jurisprudence and inspired the enactment of modern slayer statutes that now codify the principle in most jurisdictions. Doctrinally, it is a canonical example of purposive interpretation and the judicial use of equitable maxims and constructive trusts to prevent unjust enrichment. Pedagogically, the case frames enduring debates about the judicial role, the limits of textualism, and the interplay between legal rules and moral principles.
No. The court did not set aside the will. Instead, it allowed the will to stand but used equity to prevent the murderer-beneficiary from taking. The remedy functioned like a constructive trust: Elmer’s putative share was held for the benefit of the next rightful takers (the other beneficiaries or heirs), thereby preventing unjust enrichment without rewriting the will’s other provisions.
In most jurisdictions, yes. Following Riggs, states enacted slayer statutes that disqualify individuals who feloniously and intentionally kill the decedent from inheriting by will, intestacy, or as beneficiaries of nonprobate transfers. These statutes often provide that the slayer is treated as having predeceased the decedent, clarifying the distribution path and avoiding the need for ad hoc equitable remedies.
Riggs involved intentional killing. Modern statutes typically require a felonious and intentional killing. Negligence or accidental deaths generally do not trigger disqualification. If the killer lacked the requisite intent due to insanity or other defenses, the outcome may depend on statutory language and case law; some jurisdictions look to the criminal adjudication, while others make an independent civil determination by a preponderance of the evidence.
Riggs juxtaposes purposivism and textualism. The majority construed the statute in light of its purpose and moral maxims, holding that the legislature could not have intended to reward homicide. The dissent insisted on the statute’s text and warned against judicially created disqualifications. The case is a classic teaching tool for how courts justify reading a statute in the spirit rather than the letter when literal application would produce an absurd or immoral result.
Under Riggs’s equitable approach, the court effectively imposed a constructive trust on the slayer’s share for the benefit of the next entitled takers. Modern statutes often specify that the slayer is deemed to have predeceased the decedent, so the share passes to alternate beneficiaries, residuary takers, or via intestacy, and anti-lapse statutes may apply where appropriate.
Not necessarily. Many jurisdictions allow a civil court to decide slayer issues under a preponderance standard, independent of the criminal case. Thus, even if the accused is acquitted criminally, a court may still find by civil standards that the beneficiary feloniously and intentionally killed the decedent and impose slayer consequences.
Riggs v. Palmer endures because it articulates a powerful equitable constraint on the distribution of property: the law will not sanction profit from wrongdoing. By refusing to let the murderer-beneficiary take, the court preserved the integrity of the probate process and aligned the statute’s operation with fundamental moral principles.
For students, Riggs is as much a case about method as it is about inheritance. It frames perennial questions about the judiciary’s role in closing statutory gaps, the legitimacy of relying on equitable maxims, and how to reconcile the letter and spirit of the law. Its legacy is visible both in modern slayer statutes and in the broader acceptance of constructive trusts as tools to prevent unjust enrichment.