121 A.D.3d 336
N.Y. App. Div.2014Background
- Decedent Dianne Edwards left her entire estate to her daughter Deanna Edwards Palladino in her will.
- Deanna and Brandon Palladino, married in 2007, had a relationship with Brandon later murdering Dianne in 2008.
- Brandon pleaded guilty to manslaughter in the first degree in 2010, admitting intent to cause serious injury while taking jewelry from Dianne’s home.
- Deanna died intestate in 2010, approximately 14 months after Dianne’s death; her estate’s assets consisted of retirement-plan funds and anticipated inheritance from Dianne.
- Surrogate's Court concluded Brandon forfeited any claim to assets inherited through Deanna’s estate that originate from Dianne’s estate and directed disposition of assets accordingly.
- DiRusso, administrator of Deanna’s estate, appealed; Larsen cross-moved for summary judgment opposing that result.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| May Riggs v. Palmer bar a killer from indirectly inheriting via an intervening estate? | Larsen: Riggs applies to indirect as well as direct bequests. | DiRusso: extension creates enforceability concerns and lacks bright-line rules. | Riggs doctrine extended; killer barred from indirect inheritance through Deanna's estate. |
| Is there a sufficient causal link between Brandon's wrongdoing and the sought benefits to justify extension of Riggs? | Brandon’s crime created the pathway to the benefits via Deanna’s estate. | The facts require careful case-by-case analysis; not automatically transferable. | Yes; clear causal link supports extension to prevent wrongful gain. |
| Does extending Riggs in this context create unjust consequences or speculative outcomes? | Extension prevents rewarding criminal conduct and aligns with precedent like Campbell. | Could raise unforeseen enforceability issues in other fact patterns. | Not dispositive; facts here warrant extension to prevent injustice. |
Key Cases Cited
- Riggs v Palmer, 115 NY 506 (1889) (wrongdoer cannot profit from own crime; foundational Riggs doctrine)
- Campbell v Thomas, 73 AD3d 103 (2d Dept. 2010) (causal link between wrongdoing and benefits; Riggs extended to election context)
- In re Estate of Vallerius, 259 Ill App 3d 350, 629 NE2d 1185 (Ill. App. 1995) (intervening estate doctrine; supports preventing murderer’s benefit)
- Matter of Macaro, 182 Misc 2d 625 (Sur Ct, Westchester Co. 1999) (extension of Riggs-like principles in probate context)
- New York Mut. Life Ins. Co. v Armstrong, 117 US 591 (1896) (policy ownership and wrongdoing consequences guidance relevant to forfeiture notions)
- Bennett v Allstate Ins. Co., 317 NJ Super 324, 722 A2d 115 (N.J. Super. Ct. App. Div. 1998) (illustrates prevention of wrongdoer’s profits across contexts)