## Facts

- Muriel L. Holland executed a will naming her daughter, Pearl Rose Ford, as primary devisee and Pearl’s son, George Benjamin Ford, Jr., as alternate beneficiary if Pearl did not take.
- Pearl killed Muriel by stabbing her approximately 40 times, then concealed the body.
- In the criminal case, Pearl was found guilty of first-degree murder but also found not criminally responsible by reason of insanity under Maryland law.
- Maryland had no slayer statute; courts applied a common-law “slayer’s rule” barring inheritance for a “felonious and intentional” killing.
- In probate, the Orphans’ Court barred Pearl and declared George entitled to the estate.
- The Circuit Court reversed and held Pearl could take under the will.
- George appealed; the Court of Appeals granted review.

## Issues

1. Whether Maryland’s common-law slayer’s rule bars a devisee from inheriting when the devisee intentionally killed the testator but was found not criminally responsible by reason of insanity.
2. Whether a killing is “felonious” for slayer-rule purposes when criminal responsibility is negated by an insanity finding.

## Decision

- The Court of Appeals affirmed the Circuit Court.
- The slayer’s rule did not apply because a homicide is “felonious” under the rule only if the killer is criminally responsible under Maryland’s insanity standard.
- Because Pearl was found not criminally responsible, the killing was not “felonious” for slayer-rule purposes, and she could inherit as the primary devisee.

## Legal Principles

- Maryland’s common-law slayer’s rule bars inheritance only when the killing is both intentional and felonious.
- For slayer-rule purposes, “felonious” requires criminal responsibility; an insanity verdict of not criminally responsible removes the killing from the rule’s scope even if the act was intentional.
- The slayer’s rule operates as an equitable doctrine to prevent profit from wrongdoing, but its application depends on the rule’s “felonious and intentional” threshold.

## Conclusion

The court held that Maryland’s common-law slayer’s rule does not disqualify an heir or devisee who intentionally kills the decedent if the killer is adjudged not criminally responsible by reason of insanity, because the homicide is not “felonious” within the meaning of the rule.


Ford v. Ford, 307 Md. 105, 512 A.2d 389 (Md. 1986)