Weatherford insurance law attorneys and those in Mineral Wells, Springtown, Aledo, Azle, Millsap, Brock, Hudson Oaks, Cool, and other places in Parker County need to know what the “slayer’s rule” is as it relates to life insurance benefits.
This rule is exemplified in the 1987, Texas Supreme Court case, Crawford v. Coleman. Here is some background.
This is an insurance disqualification case involving the distribution of proceeds of life insurance policies.
On May 14, 1979, Sandra Shoaf was stabbed to death by her husband, Cornelius Shoaf. Sandra’s life was insured under four insurance policies, each designating Cornelius as the primary beneficiary. The trial court disqualified Cornelius from receiving Sandra’s death benefits because the jury found that Cornelius willfully caused Sandra’s death.
One policy named Cornelius Shoaf as the “insured,” and Sandra as the “insured spouse” under a family plan of insurance included in the policy. The preprinted language of the policy provides that the “beneficiary” of the insured spouse is “the insured, if living; if not living, the surviving children of the insured.”
The law says the interest of a beneficiary in a life insurance policy shall be forfeited when the beneficiary is the principal or an accomplice in willfully bringing about the death of the insured. When such is the case, the nearest relative of the insured shall receive said insurance. This is currently found in Texas Insurance Code, Section 887.205. This statute currently reads:
(b) A beneficiary of a life insurance certificate forfeits the beneficiary’s interest in the certificate if the beneficiary is the principle or an accomplice in wilfully bringing about the death of the insured. The nearest relative of the insured is entitled to the proceeds of an insurance certificate forfeited under this section.
In this case, the fight was over which relative was entitled to the proceeds of the insurance policies.
The Crawfords argued that the proceeds of the Equitable policy and the Metropolitan policy covering Sandra’s life are distributable to them because they are Sandra’s “nearest relative” upon Cornelius’s disqualification. The Crawfords read Texas law as directing proceeds to the contingent beneficiary only when the contingent beneficiary is expressly named and is an object of the deceased insured’s obvious intent. Cornell argues that he should receive the proceeds because he is the contingent beneficiary under these policies, and distribution to the nearest relative is not triggered until all beneficiaries are disqualified. The Court agreed that the Crawfords should receive the proceeds on Sandra’s life, but for reasons different than those offered by the Crawfords.
It is undisputed that Cornelius had forfeited any interest in the proceeds because he willfully brought about Sandra’s death. Affidavits signed by the Crawfords indicated they are Sandra’s nearest relatives.
The court stated that the law as written by the State Legislature makes clear who is to receive the proceeds of the insurance policies at issue.
This case is still good law and makes it clear that a beneficiary who willfully participates in bringing about the insured’s death, either as a principle or as an accomplice, forfeits any right to benefits. The benefits are payable to any innocent contingent beneficiary or to the insured’s nearest relative.
Sometimes there is an issue about whether or not the beneficiary participated in bringing about the death of the insured. That is certainly a time when an experienced Insurance Law Attorney should be consulted.
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