Riggs v. Palmer, 115 N.Y. 506, 22 N.E. 188 (N.Y. 1889)
Riggs v. Palmer is a canonical Trusts & Estates and jurisprudence case that crystallizes the equitable slayer rule: a person should not be allowed to profit from his own wrong.
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).
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.