State Treasurer v. Snyder
294 Mich. App. 641
| Mich. Ct. App. | 2011Background
- Defendant Wayne Snyder has been incarcerated since 1999 at state expense.
- Snyder received $2,500 as beneficiary of his mother’s life insurance policy.
- The State filed an SCFRA reimbursement action under MCL 800.404(1) seeking repayment of incarceration costs.
- Snyder filed a purported disclaimer of property interest under the DPIL (MCL 700.2901 et seq.) purporting to disclaim all interest in the life insurance proceeds.
- The circuit court held the disclaimer void due to Snyder’s knowledge of the proceeds and acceptance before filing, and ordered 90% of the proceeds to be applied to SCFRA reimbursement; case dismissed.
- On appeal, Snyder argued the disclaimer was permissible; the issue is whether SCFRA bars such disclaimer and whether proceeds are assets under SCFRA.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does SCFRA bar a prisoner’s DPIL disclaimer of life-insurance proceeds? | State argues SCFRA bars any disclaimer that would defeat reimbursement. | Snyder argues DPIL allows disclaimer regardless of SCFRA. | Yes; SCFRA bars the disclaimer. |
| Are life-insurance proceeds assets subject to SCFRA even if disclaimer is attempted? | State asserts proceeds are assets owed to prisoner under SCFRA. | Snyder contends disclaimer excludes proceeds from assets. | Yes; proceeds are assets due to prisoner under SCFRA, unaffected by disclaimer. |
Key Cases Cited
- State Treasurer v. Schuster, 456 Mich. 408 (1998) (SCFRA broad right to recover costs; defines assets and reimbursement scope)
- Sheko v. State, 218 Mich. App. 185 (1996) (prisoner cannot defeat SCFRA reimbursement; DPIL limits not applicable)
- Aetna Life Ins. Co. v. Owens, 318 Mich. 129 (1947) (premeditation of receipt irrelevant; proceeds due counted as assets)
- Dogariu v. Dogariu, 306 Mich. 392 (1943) (receipt/possession status not determinative for assets under SCFRA)
- Michigan Tp Participating Plan v. Fed. Ins. Co., 233 Mich. App. 422 (1999) (de novo statutory interpretation review; legislative intent)
- Hess v. Cannon Twp., 265 Mich. App. 582 (2005) (dispositive issue resolved; DPIL/SCFRA interaction)