The U.S. District Court for the Northern District of New York found the Employee Retirement Income Security Act (ERISA) does not preempt the state’s slayer rule, prohibiting a killer from profiting from his crime. The decedent’s eldest son, who was named as sole beneficiary of his father’s life insurance, argued that his age and state of extreme emotional disturbance at the time of the killing are factors that, when taken into consideration, should allow him to receive his father’s life insurance benefits.
However, the district court noted a previous court explained emotional disturbance merely lessens the degree of crime; it “neither excuses nor absolves the culpability of the offender . . . nor does such element render the killing unintentional or accidental. Accordingly, such conviction precludes inheritance or any profiting from such wrong.” U.S. District Judge Lawrence E. Kahn wrote that ultimately, because emotional disturbance does not impair one’s ability to understand the nature and quality of an act, it cannot fall under the exception to the slayer rule.
In addition, as long as the defendant meets the age requirement for the substantive offense, courts have refused to mitigate the slayer rule because the offender was adjudicated as a juvenile defendant.
Kahn noted where a beneficiary is disqualified from life insurance benefits under the slayer rule, he is treated by the law as having predeceased the decedent. The decedent’s plan dictates if no beneficiary is living when he dies, then his benefits will be paid to his surviving children if he has no surviving spouse. Decedent was unmarried at the time of his death; therefore, the Court finds his other son should receive his life insurance benefits in its entirety.
The younger son filed a motion for summary judgment against the older son after Union Security Life Insurance Company of New York filed a complaint for interpleader relief after both sons of the deceased filed competing claims for their father’s life insurance benefits.
The case is Union Security Life Insurance Co. v. JJG-1994, N.D.N.Y., No. 1:10-cv-00369-LEK-RFT.
Last year, a federal judge in New Jersey used the slayer rule in that state to rule that a man convicted for his wife’s death in a murder-for-hire scheme should not be entitled to her pension benefits (see Convicted Killer Barred from Getting Dead Wife’s Pension). Another district court previously ruled that the estate of a woman killed by her husband who then committed suicide is not due surviving spouse benefits from his pension plan (see Woman Killed by Husband Who Committed Suicide not a Surviving Spouse).
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