Robert Lawrence v. Joe W. Bailey II, Administrator of the Estate of Steven Ross Lawrence
01-19-00799-CV
| Tex. App. | Jul 5, 2021Background
- Hartford paid $640,035.06 in life-insurance proceeds for Steven Lawrence into the trial-court registry and filed interpleader naming multiple claimants, including Steven’s brother Robert and Steven’s son Ross (the named contingent beneficiary).
- Steven and his wife LaQuita were murdered in 2013; Ross was indicted for their murders. The Slayer Statute (Tex. Ins. Code §§ 1103.151–.152) can disqualify a beneficiary who wilfully caused the insured’s death.
- Robert sued for a declaratory judgment that, if Ross forfeited his interest under the Slayer Statute, Robert (as nearest living relative) is entitled to the proceeds; summary-judgment efforts were denied and the case was set for jury trial.
- The administrator of Steven’s estate filed a one-page motion (with no substantive legal briefing) to distribute the registry funds to the estate; the trial court granted the motion without any recorded hearing or notice to Robert and closed the registry account.
- Robert moved for a new trial asserting he received no notice of the dispositive consideration and thus was denied due process; the trial court denied the motion the next business day.
- The court of appeals held Robert had standing to seek declaratory relief and concluded the trial court violated Robert’s due- process rights by disposing of the funds without notice; it reversed the distribution order and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument (Robert) | Defendant's Argument (Estate / Admin) | Held |
|---|---|---|---|
| Standing to seek declaratory relief under the Slayer Statute | Robert: He has a justiciable interest—he is the insured’s nearest living relative and claims entitlement if Ross forfeits under the Slayer Statute | Estate: Robert lacks standing because he is not a named beneficiary and other proceedings (criminal, probate) bear on entitlement | Held: Robert has standing; standing is met under UDJA and should be decided on the merits, not dismissed for lack of jurisdiction |
| Whether granting the administrator’s motion without notice violated due process / denial of new trial | Robert: Trial court considered and granted the dispositive motion without notice or hearing, depriving him of notice and opportunity to be heard; new trial warranted | Estate: Implicitly argued trial court’s order was proper (on appeal focused more on merits than notice) | Held: Court found a due-process violation—Robert lacked notice of consideration; trial court abused its discretion in denying new trial; distribution reversed and remanded |
| Whether the estate established entitlement to the proceeds (merits) | Robert: Estate’s motion contained no legal basis; estate did not establish entitlement; Ross forfeiture and nearest-relative status must be adjudicated | Estate: Policy language and default contingency mean estate would receive proceeds if named beneficiaries are disqualified | Held: Court did not decide the merits; resolution on due-process grounds was dispositive and remanded for further proceedings |
Key Cases Cited
- Peralta v. Heights Med. Ctr., Inc., 485 U.S. 80 (due process requires notice before disposing of a party’s property)
- Mullane v. Cent. Hanover Bank & Tr. Co., 339 U.S. 306 (notice must be reasonably calculated to apprise interested parties)
- Tex. Dep’t of Transp. v. City of Sunset Valley, 146 S.W.3d 637 (standing reviewed de novo)
- Meyers v. JDC/Firethorne, Ltd., 548 S.W.3d 477 (standing is jurisdictional and may be raised on appeal)
- Austin Nursing Ctr., Inc. v. Lovato, 171 S.W.3d 845 (standing requires a justiciable interest)
- Lehmann v. Har-Con Corp., 39 S.W.3d 191 (defining final judgment for appealability)