## Facts

- Mary Severson bought a $200,000 term life-insurance policy on her life; premiums were paid with community funds during her marriage to Larry Severson.
- Mary initially designated Larry as primary beneficiary, then later changed the beneficiary to her mother, Carolyn Diaz.
- Larry murdered Mary and was convicted of first-degree murder.
- After Mary’s death, Diaz claimed the full policy proceeds as the named beneficiary.
- Larry asserted entitlement to one-half of the proceeds under Idaho community-property principles because community funds paid the premiums and the spouse’s share would otherwise vest at death.
- The insurer filed an interpleader action and deposited the proceeds with the court due to competing claims and the possible application of Idaho Code § 15-2-803.

## Issues

1. Whether Idaho Code § 15-2-803 bars a spouse convicted of feloniously and intentionally killing the insured spouse from receiving any portion of life-insurance proceeds, including an asserted one-half community-property share.
2. Whether life-insurance proceeds and community-property-based claims fall within § 15-2-803(b)’s bar on acquiring “property or any other benefit” as a result of the victim’s death, even if § 15-2-803(e) (devise/legacy/intestacy) does not apply.
3. Whether a pending appeal from the killer’s criminal conviction prevents the civil court from applying the slayer statute or requires staying the interpleader action.

## Decision

- The Idaho Supreme Court affirmed the judgment awarding the entire $200,000 in proceeds to Diaz and denying Larry any share.
- The court held that § 15-2-803(b) prevents Larry from receiving any benefit resulting from Mary’s death, including any community-property-based interest in the policy proceeds.
- The court rejected the argument that a pending criminal appeal barred application of the slayer statute; the civil court could proceed based on the existing conviction and, if necessary, could determine felonious and intentional killing under a civil standard.

## Legal Principles

- Idaho Code § 15-2-803(b) bars a person who feloniously and intentionally kills another from acquiring “property or any other benefit” that accrues or is increased because of the victim’s death.
- The statutory bar extends beyond probate transfers and can reach contractual benefits, including life-insurance proceeds payable on the victim’s death.
- A claimed community-property share that would vest at the insured’s death is a “benefit” arising from the death and is barred when asserted by the killer.
- A criminal conviction for the killing may be relied on in the civil proceeding; the pendency of an appeal does not require the civil court to delay applying the statute.

## Conclusion

The court held that Idaho’s slayer statute prevents a spouse convicted of murdering the insured from taking any portion of life-insurance proceeds, even if community-property rules would otherwise grant a vested one-half share at death, and it permitted civil resolution without awaiting the outcome of the criminal appeal.


United Invs. Life Ins. Co. v. Severson, 143 Idaho 628, 151 P.3d 824 (Idaho 2007)