Riggs v. Palmer

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Following is the case brief for Riggs v. Palmer, New York Court of Appeals, (1889)

Case summary for Riggs v. Palmer:

  • Francis Palmer executed a will, leaving his estate to his daughter and grandson.
  • Palmer’s grandson, Elmer Palmer, poisoned Palmer to death and was later convicted of his murder.
  • Palmer’s daughters brought a claim requesting the court to find Elmer’s share void. The court denied the claim and the daughters appealed.
  • The court of appeals held that permitting Elmer to inherit would be an absurd outcome and as a result, the statute does not apply to this will.

Riggs v. Palmer Case Brief

Statement of the facts:

Fransis Palmer executed a will leaving his estate to his two daughters, Mrs. Preston and Mrs. Riggs and his grandson, Elmer Palmer.  Shortly after, Francis Palmer remarried, but drafted a prenupt. Elmer Palmer poisoned his grandfather to death in 1882, and was later convicted of murder. Mrs. Preston and Mrs. Riggs brought a claim to consider the provisions of the will which included Elmer as void. In response, the trial court dismissed the suit.

Procedural History:

Mrs. Riggs and Mrs. Preston appealed the trial court’s decision to the state court of appeals.

Rule of Law or Legal Principle Applied:

For the purpose of preventing an absurd result, in interpreting a statute, a court may stray from the statute’s plain text.

Issue and Holding:

Whether a court may stray from a statute’s text to prevent an unjust result? Yes.

Judgment:

The New York court of appeal’s reversed the trial court’s judgment.

Reasoning:

The court held that when enforcement of a statute renders an absurd or unreasonable result, a court may interpret the statute in a manner which displays the lawmakers’ true intentions. Here, the state Statute of Wills is clear is outlining who may inherit.

Since Palmer is a named beneficiary in a validly executed will, the law permits him to inherit the estate. The issue is, a murderer cannot reasonably inherit from his victim.

When examining the statutory intent, lawmakers wanted to make sure that beneficiaries mentioned in the will would receive the property they were left. The same cannot be said of a beneficiary who murdered the testator to expedite receiving his inheritance.

Concurring or Dissenting opinion:

Dissenting (Gray):

Since each state’s statute outlines the circumstances in which a will may be revoked or altered after a testator’s death, it is implied that any other circumstances will not be considered. Here, the facts fail to meet the set statutory requirements. Criminal punishment is sufficient, additional punishment is not needed.

Significance:

This case set the precedent for when straying from a statute would be permissible, even when the content is clear. To prevent an absurd result, it is ok for a court to interpret a statute in a way which establishes the statutory intent.

Student Resources:

http://www.courts.state.ny.us/reporter/archives/riggs_palmer.htm
http://publishing.cdlib.org/ucpressebooks/view?docId=ft9q2nb693&chunk.id=d0e1366&toc.id=d0e1282&brand=ucpress;query=socialized%20medicine