common law preventing a son from inheriting pension benefit funds in a plan managed by ERISA (Employee Retirement Income Security Act of 1974) when he murdered his parent. Standard Ins. co. v. Guy, 115 F.4th 518 (6th Cir. 2024). The case seems to be replay of the famous opinion by the New York Court of Appeals in Riggs v. Palmer, 22 N.E. 188 (N.Y. 1889).
The Riggs opinion has this famous quote:
“But it never could have been [the lawmakers’] intention that a donee who murdered the testator to make the will operative should have any benefit under it. If such a case had been present to their minds, and it had been supposed necessary to make some provision of law to meet it, it cannot be doubted that they would have provided for it.” The Sixth Circuit viewed ERISA as “silent or ambiguous” on the question of whether a slayer can benefit by inheriting ERISA funds. It noted that federal courts had long applied the “slayer rule” in the 19th century in insurance cases and that the federal courts in the 20th century had followed suit. The Sixth Circuit assumed that Congress, in passing the ERISA statute, “legislated with an expectation” that longstanding common law rules would apply unless the statute provided otherwise.