Case library · Slayer rule

Mutual Life Insurance Co. of New York v. Armstrong (1886)

The early Supreme Court statement that a person who kills the insured cannot collect the life insurance.

Background

A man who held a policy on Armstrong’s life was convicted of his murder and executed. Armstrong’s estate sued the insurer for the proceeds.

What the Court held

The Court said that whatever the killer’s motives in obtaining the policy, he forfeited all rights under it when he murdered the insured to secure payment. It would be a reproach to the law, the Court wrote, if a person could recover insurance money payable on the death of someone whose life he had feloniously taken.

Why it matters today

The principle survives today, now mostly by statute. Those statutes usually treat the killer as having died first, so the money passes to the contingent beneficiary or the estate. They differ on the proof required, and some allow a civil finding without a criminal conviction. When a beneficiary is suspected, the insurer often pays the money into court and lets the court decide who receives it, which can delay payment for everyone else.

Read the opinion

Mutual Life Ins. Co. of New York v. Armstrong, 117 U.S. 591 (1886) (Cornell LII).

Not legal advice. This page summarizes general rules and the specific statutes cited. Your policy's wording, the state whose law applies, and whether the coverage came through an employer can all change the result. See the disclaimer and editorial policy.