## Facts

- Francis B. Palmer executed a will leaving small legacies to his daughters and the residue to his grandson, Elmer E. Palmer, subject to support for Elmer’s mother.
- Elmer lived with his grandfather and knew the will favored him.
- Fearing the testator might revoke or change the will, Elmer intentionally killed his grandfather by poisoning to obtain the inheritance sooner.
- Elmer was convicted of murder.
- The daughters sued to prevent Elmer from taking any interest under the will, arguing a wrongdoer should not profit from his wrongdoing.

## Issues

1. Whether a beneficiary who intentionally kills the testator to accelerate inheritance may take under an otherwise valid will when no statute expressly disqualifies the killer.
2. Whether courts may construe wills and inheritance statutes to avoid unjust results inconsistent with legislative purpose, even if the statutory text would otherwise permit recovery.

## Decision

- The New York Court of Appeals reversed the dismissal and granted relief to the daughters.
- The court held Elmer could not take any benefit under the will because he procured the benefit by intentionally killing the testator.
- The court treated the will’s gift to Elmer as inoperative as to him, so the estate passed as though his interest were excluded.

## Legal Principles

- A person may not profit from intentional wrongdoing; equity will not allow a killer to take from the victim’s estate.
- Statutes are construed in light of their purpose; what falls within the letter of a statute may be excluded when it falls outside the lawmakers’ intended scope.
- Courts may reject a literal reading that would produce an absurd or unjust result clearly not contemplated by the legislature in enacting the succession scheme.
- Dissenting view: wills and revocation statutes are exhaustive, and courts should not add nonstatutory disqualifications; any disinheritance rule should come from the legislature.

## Conclusion

The court barred a murderer from inheriting under the victim’s will, reasoning that succession statutes should not be applied to reward intentional homicide and that equitable principles and legislative purpose require denying benefits obtained through such wrongdoing.


Riggs v. Palmer, 22 N.E. 188 (N.Y. 1889)