Riggs v Palmer Case Summary

Riggs v. Palmer case brief summary A. Facts: young guy kills his grandfather in order to get his inheritance, now wants his inheritance; notes that will was duly executed, will laws say nothing about murder B. Interpretive Arguments: 1. From Plaintiff: a. The purpose of wills is for people to dispose of their property as they like, testator clearly expressed his desire to give P his property, no reason to undo that by P’s actions 2. Legislative Intent a. Cannot be intent to benefit murderers 3. Statutory Purpose a. Purpose of wills is to allow testator to dispose of property as they like → arguably he may not have here, since he could have changed his mind until he died naturally, but that was cut off by his being killed b. Meant for the ‘orderly, peaceable, and just’ devolution of property – could not then contemplate such a disorderly situation → absurd results again Transcript of Riggs v Palmer (1889) Riggs v Palmer (1889) Majority Opinion Judge Robert Earl: -through interpretation, judges must try to match intent of the will as best they can because it is impossible for lawmakers to consider every possible case *Qui haeret in litera, haeret in cortice, "He who adheres to the letter, adheres to the bark" (if you stick to the literal meaning of the law you will not be able to reach the substance) Plaintiffs : Mrs. Riggs and Mrs, Preston, daughters of Francis B. Palmer Defendant : Elmer E. Palmer, grandson of Francis B. Palmer Context : Elmer poisons his grandfather because he learns his grandfather is planning on changing his will and he wants to remain the main beneficiary Question : Is the will invalid because Elmer murdered his grandfather or is it valid because the law is silent on the issue? Majority Opinion -Laws are passed "for the orderly, peaceable, and just devolution of property" -The intention of testators is surely not to grant their estates to beneficiaries who murder them -"We need not, therefore, be much troubled by the general language contained in the laws." ex. "In the Decalogue no work shall be done upon the Sabbath, and yet, giving the command a rational interpretation founded upon its design, the Infallible Judge held that it did not prohibit works of necessity, charity or benevolence on that day" Methods of Interpretation Constrain : Take the spirit of the statue to make a decision that narrows its original scope Expand : Take the spirit of the statue to make a decision that goes past its original scope Void Uphold Court of Appeals of New York Major Themes -maxims and principles vs. legal rules -law covering too much vs. law covering too little -enlarging judicial power vs. limiting judicial power Dissenting Opinion Discussion Questions -We are bound by the rules of law established by the legislature -The will is valid because it is in full compliance with the law -In the absence of legislation the court cannot allow the remedial justice the plaintiffs seek -Intention to revoke a will does not have the effect of revocation Dan v. Brown Gains v. Gains, 1820 Leaycraft v. Simmons, 1854 Clingan v. Mitcheltree -Double Jeopardy -The laws do not warrant the court making a will for the testator Should judges be able to decide cases based on universal natural laws when it is unclear whether or not they exist? Does depriving Elmer of the estate constitute a case of double jeopardy because he is already serving out his criminal law punishment? Majority Opinion -All laws are controlled by fundamental maxims of common law dictated by public policy and have their foundation in universal law administered in all civilized countries ex. "no one should be able to profit from their own crime" -New York Mutual Life Insurance Company v. Armstrong o Justice Field: even assuming life insurance was gotten with good intentions, murderer forfeited all rights under policy when he murdered the assured o It would be a reproach to jurisprudence if one could recover insurance money on someone whose life he had feloniously taken. -If a will is procured by force/fraud or is against public policy it is void -No certainty: • murderer would survive testator • testator would not have changed the will Majority Opinion -The general principles of natural law dictate that "one cannot take property by inheritance or will from an ancestor or benefactor whom he has murdered" -This case does not inflict upon Elmer any greater or other punishment for his crime than the law specifies. It takes from him no property, but simply holds he shall not acquire property by his crime Final Judgment: plaintiffs are the true owners of the real and personal estate left by the testator -Expands law based on principles