## Facts

- Muriel L. Holland executed a will devising property to her daughter, Pearl Rose Holland Ford, with her grandson, George Benjamin Ford, Jr., as an alternate beneficiary.
- Pearl killed Holland by stabbing her approximately forty times, then wrapped the body and placed it in the backyard.
- In the related criminal proceeding, Pearl was found guilty of first-degree murder but adjudged not criminally responsible by reason of insanity.
- George sought to disqualify Pearl from taking under the will, arguing that Maryland’s common-law slayer’s rule should apply and that he should inherit instead.

## Issues

1. Whether Maryland’s common-law slayer’s rule bars inheritance when the beneficiary killed the decedent but was found not criminally responsible by reason of insanity.
2. Whether a killing can be “felonious” for slayer’s-rule purposes absent criminal responsibility under Maryland’s insanity standard.

## Decision

- The Court of Appeals of Maryland affirmed the circuit court’s judgment allowing Pearl to inherit under the will.
- The court held the slayer’s rule applies only to a “felonious and intentional” homicide.
- A homicide is “felonious” for slayer’s-rule purposes only if the killer is criminally responsible under Maryland’s criminal insanity test.
- Because Pearl was adjudged not criminally responsible, the slayer’s rule did not bar her from taking under the will.

## Legal Principles

- Maryland applies a common-law slayer’s rule grounded in equity: a person may not profit from their own crime or culpable wrongdoing.
- The slayer’s rule in Maryland disqualifies a beneficiary only upon proof of a “felonious and intentional” homicide.
- “Felonious,” in this context, requires criminal responsibility; an insanity adjudication negates the felonious element even if the act was intentional.
- Absent statutory direction, courts apply the slayer’s rule within the limits set by prior Maryland precedent and the state’s criminal responsibility framework.

## Conclusion

Maryland’s slayer’s rule does not disqualify a beneficiary who killed the testator when the beneficiary was found not criminally responsible by reason of insanity; the homicide is not “felonious” for purposes of the rule, so the beneficiary may inherit under the will.


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