Francis B. Palmer executed a will leaving small legacies to his two daughters (the plaintiffs, including Mrs. Riggs) and devising the bulk of his estate to his grandson, Elmer E. Palmer, who was also named as a principal beneficiary. After learning that his grandfather intended to revoke or alter the will to reduce or eliminate his share, Elmer intentionally poisoned Francis to prevent the change and secure his inheritance. The will, validly executed, was offered for probate. The daughters then sued in equity to prevent Elmer from taking under the will, arguing that it would violate fundamental public policy to allow a murderer to profit by his own wrong. The relevant New York probate and descent statutes did not contain any express provision disqualifying a beneficiary who feloniously caused the testator's death. The lower courts concluded the will had to be enforced according to its terms and the statutes as written. On appeal, the New York Court of Appeals was asked to decide whether, notwithstanding the statutory silence, equity and public policy barred Elmer from inheriting under the will he ensured would take effect by committing murder.
Whether a beneficiary who intentionally murders the testator may inherit under the testator's will when the governing probate statutes are silent on any such disqualification.
Courts will not permit a person to profit from his own wrong. Interpreting probate and descent statutes in light of common-law maxims and public policy, a beneficiary who intentionally kills the testator is equitably barred from taking under the will; the estate is to be distributed as if the slayer had predeceased the testator (or in a manner that otherwise prevents the wrongdoer from benefiting).
No. A beneficiary who intentionally kills the testator is disqualified from inheriting under the will. The will is construed and the estate distributed as though the killer predeceased the testator, thereby passing the property to the next lawful takers (here, the testator's daughters).
The Court of Appeals grounded its decision in foundational equitable maxims and the broader purpose of the statutory scheme. It reasoned that legal rules must be construed to avoid absurd and immoral results that the legislature could not have intended, even if the text is silent on a specific contingency. Permitting Elmer to take would allow him to profit from his own crime—an outcome encapsulated in long-settled principles: no one shall be permitted to profit by his own fraud, to take advantage of his own wrong, to found a claim upon his own iniquity, or to acquire property by his own crime. These maxims, the court explained, are not mere aphorisms but animating principles that inform statutory application. The court emphasized that the aim of probate statutes is to carry out a testator's lawful intent, not to reward wrongdoing. Because Francis's will was executed on the premise that he would live to revise or revoke it, Elmer's act of murder prevented the exercise of that freedom and subverted the statutory framework. Reading the statutes to compel distribution to the murderer would yield an intolerable mismatch between legal form and justice. Accordingly, the court recognized an implied exception: when the beneficiary intentionally causes the testator's death, equity intervenes to prevent the transfer to the wrongdoer, effectively treating the wrongdoer as having predeceased the testator. The court rejected the contention—pressed by the dissent—that strict textual fidelity precludes judicially created exceptions. The majority responded that courts routinely harmonize statutes with common-law principles and public policy to avert outcomes the legislature would not have sanctioned had it addressed the specific scenario. It further noted that denying the murderer's inheritance is not an additional criminal penalty but an equitable limitation on unjust enrichment. In sum, fidelity to statutory purpose and the common law's moral architecture required barring Elmer from taking.
Riggs v. Palmer is foundational to the slayer rule and a staple of Trusts & Estates. It shows how courts deploy equitable principles—often via constructive trust or analogous remedies—to prevent unjust enrichment when statutory text is silent. The case is equally significant for interpretive theory: it juxtaposes purposivism and policy-sensitive adjudication (majority) against textualism and separation-of-powers concerns (dissent). Modern jurisdictions largely codify the slayer rule, but Riggs remains the touchstone for the principle that legal entitlements cannot be secured through one's own wrongdoing.
Riggs v. Palmer endures because it marries equitable principle to statutory purpose, preventing a morally grotesque outcome—inheritance by a murderer—despite statutory silence. The court's approach illuminates how equity polices the boundaries of legal entitlements to avoid unjust enrichment and safeguard the integrity of testamentary freedom.