Applying the common law “slayer rule,” a federal district court in New York held that a beneficiary of an ERISA-governed life insurance plan forfeit his claim to insurance proceeds after he pled guilty to murdering the policyholder. Metropolitan Life Ins. Co. v. Little, E.D.N.Y., No. 13-cv-1059-BMC, Aug. 17, 2013. The policy holder, Rosemary Little, named her son as a 60% beneficiary, and her grandson a 40% beneficiary. Rosemary’s grandson pled guilty to murdering her.
After paying Rosemary’s son 60% of the benefit, MetLife initiated an interpleader action seeking a direction from the court as to how to distribute the remaining 40% of the benefits. The son filed a counterclaim and motion for summary judgment seeking the remaining 40% of the benefit. The Court held that the grandson forfeited any claim to the remaining benefits because the slayer rule, a common law principle dating to the late nineteenth century, precludes an individual who causes the death of an insured from recovering under the insured’s policy. The court thus ordered that the remaining proceeds be paid to the son, the only other named beneficiary under the policy.