- Amount
- $584,000 (benefits awarded to our two clients in equal shares)
- Counsel
- Interpleader Law
- Result for
- The insured's brother and sister, our clients
- Case
- Standard Insurance Co. v. Guy
- Court
- U.S. District Court, Eastern District of Tennessee; affirmed by the U.S. Court of Appeals for the Sixth Circuit
- Docket
- No. 2:18-cv-00074; 6th Cir. No. 21-5562, 115 F.4th 518
- Decided
- August 19, 2024
- Issue
- Whether a beneficiary convicted of killing an ERISA plan participant may collect the plan's benefits
A mother insured herself, and her husband as a dependent, under employer group life and accidental death plans governed by ERISA. Their son killed both parents and was convicted of first-degree murder. His 2020 murder trial in Knox County drew national attention, and Court TV broadcast and archived the full trial. The insurer filed an interpleader, and if the son was disqualified, the mother’s benefits would pass to her brother and sister.
We represented the mother’s siblings. After the conviction, the district court refused to keep the case on hold while the son appealed. It held him disqualified under Tennessee’s slayer statute, under which a conviction is conclusive, or in the alternative under federal common law. It entered judgment awarding the mother’s benefits to our clients.
The son appealed, arguing that ERISA requires payment to the designated beneficiary. In a published opinion, the Sixth Circuit affirmed. It held that the rule requiring payment to the designated beneficiary is not absolute, and that if ERISA preempts the state statute, the federal common-law slayer rule fills the gap and leads to the same result.
What it shows. In the Sixth Circuit, a beneficiary who kills an ERISA plan participant cannot collect the benefits, whichever body of law applies.
Read the court's order
- Memorandum opinion and order (May 20, 2021) (PDF)
- Judgment (May 20, 2021) (PDF)
- Sixth Circuit opinion (Aug. 19, 2024) (PDF)
For a detailed legal summary of this decision, see interpleader.com's decisions library.
Past results do not guarantee a similar outcome. This summary describes the court's ruling; it is not legal advice about any other case.
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