District Court Upholds Slayer Statute to Deny ERISA Life Insurance Proceeds to Convicted Killer

In Stacy v. The Hartford, No. 4:25-CV-6, 2025 WL 2860049 (E.D. Tenn. Oct. 9, 2025), Judge Travis R. McDonough of the U.S. District Court for the Eastern District of Tennessee issued a memorandum opinion granting both The Hartford’s motion for interpleader and dismissal, and the plaintiff’s motion for judgment on the pleadings. The court’s decision confirms that Tennessee’s “slayer statute” bars a beneficiary who intentionally kills another insured from receiving life insurance proceeds under an ERISA-governed plan. The ruling also demonstrates how federal courts navigate ERISA preemption and state “slayer” laws when determining entitlement to policy benefits.

Background

The dispute arose from a tragic sequence of events involving an ERISA-covered life insurance policy issued by The Hartford to policyholder Savannah Johnson. Two individuals—Quentin Stacy and Steven Brian Henley—were designated as beneficiaries under the policy. In 2022, Henley shot and killed Quentin Stacy. Subsequently, Johnson died of natural causes in August 2023. After Johnson’s death, Henley remained a named beneficiary under the policy.

Amanda Stacy, the administrator of Quentin Stacy’s estate, brought suit in the Circuit Court for Franklin County, Tennessee, both individually and on behalf of Stacy’s minor children. She sought to recover any proceeds payable to Henley under the policy, asserting that Tennessee’s slayer statute, Tenn. Code Ann. § 31-1-106, barred Henley from receiving benefits because he intentionally killed another beneficiary. She also argued, in the alternative, that any proceeds payable to Henley should be used to satisfy a $6.25 million wrongful death judgment previously entered against him.

The Hartford removed the case to federal court on the basis that the life insurance policy was governed by the Employee Retirement Income Security Act of 1974 (“ERISA”), 29 U.S.C. § 1001 et seq., and filed an interpleader crossclaim. Hartford sought permission to deposit the policy proceeds—approximately $88,000—into the court’s registry and to be dismissed from the case with prejudice.

Hartford’s Interpleader Motion

Under Federal Rule of Civil Procedure 22, an interpleader allows a stakeholder facing competing claims to the same fund to seek judicial resolution of the dispute while avoiding multiple liabilities. The court observed that Hartford was properly exposed to potential double liability because both Stacy and Henley could claim entitlement to the same life insurance proceeds. Finding no evidence of bad faith or independent liability on Hartford’s part, and noting that neither Stacy nor Henley opposed Hartford’s motion, the court granted the insurer’s request to deposit the funds into the court’s registry. Upon deposit, Hartford was dismissed from the action and enjoined from further litigation over the same benefits.

Stacy’s Motion for Judgment on the Pleadings

Turning to Stacy’s motion, the court applied the Rule 12(c) standard, which mirrors that for a Rule 12(b)(6) motion to dismiss. A plaintiff is entitled to judgment on the pleadings when, accepting all well-pleaded facts in the defendant’s answer as true, the complaint still states a clear cause of action. Under Rule 8(b)(6), any allegation not denied in a required responsive pleading is deemed admitted.

Henley’s answer contained no denials of the complaint’s allegations. Instead, he simply asserted a claim to “family property” unrelated to the policy. Henley also failed to oppose Stacy’s motion for judgment on the pleadings. Under Sixth Circuit precedent and the local rules of the Eastern District of Tennessee, such failure constituted a waiver of opposition. Accordingly, the court deemed Stacy’s factual allegations admitted and proceeded to determine whether those facts entitled her to relief.

Application of the Tennessee Slayer Statute

The court held that Tennessee’s slayer statute, Tenn. Code Ann. § 31-1-106, squarely applied. The statute provides that an individual who “feloniously and intentionally kills” the decedent forfeits any right to receive property or benefits “with respect to the decedent’s estate.” Because Henley killed Quentin Stacy, one of the policy’s beneficiaries, he was barred from recovering any proceeds under the policy. The court found no reason to disturb that outcome, particularly in light of Henley’s admissions and lack of opposition.

Given the application of the slayer statute, the court did not reach Stacy’s alternative theory—that she could execute against Henley’s share of the proceeds to satisfy the prior wrongful death judgment. Nonetheless, the opinion implicitly confirmed that such equitable remedies remain viable where the statutory disqualification might not otherwise apply.

Conclusion and Practical Takeaways

The decision reinforces the principle that ERISA does not preempt state slayer statutes, which operate as neutral rules of property distribution rather than as alternate enforcement mechanisms for benefits claims. This aligns with long-standing federal precedent recognizing that ERISA’s broad preemption clause yields to state laws preventing killers from profiting from their crimes.

For practitioners, Stacy v. The Hartford offers several lessons:

1. Interpleader as a Shield for Insurers: The Hartford’s proactive use of interpleader allowed it to fulfill its obligations under ERISA while avoiding entanglement in a morally and factually charged beneficiary dispute.
2. Importance of Pleadings Discipline: Henley’s failure to properly answer or respond underscores how admissions by default can determine the outcome at the pleading stage.
3. ERISA and State Law Harmony: The ruling illustrates that federal courts routinely apply state inheritance disqualification statutes within ERISA’s framework without triggering preemption conflicts.

For individuals seeking life insurance benefits—especially under employer-sponsored ERISA plans—Stacy v. The Hartford provides several key takeaways:

1. Expect Interpleader When Beneficiary Disputes Arise: When multiple individuals claim entitlement to the same life insurance proceeds, insurers often file an interpleader action to have a court determine the rightful recipient. This procedure is not necessarily adversarial—it allows the insurer to avoid conflicting obligations and ensures that benefits are distributed according to law.
2. State Law Can Determine Who Is Entitled to Benefits: Even though ERISA governs the administration of benefit plans, state laws like Tennessee’s slayer statute still apply to questions of entitlement. These laws operate as neutral rules of property ownership, meaning they are not preempted by ERISA. Claimants should be aware that state inheritance or disqualification statutes can affect who ultimately receives policy proceeds.
3. Procedural Precision Is Critical: As this case demonstrates, failing to respond to motions or properly contest allegations can result in a default judgment or deemed admissions. Claimants should take all pleadings seriously and seek experienced ERISA counsel early to ensure that procedural deadlines and substantive arguments are fully preserved.
4. Insurer Neutrality Does Not Mean Claim Denial: When an insurer like The Hartford initiates interpleader, it is not necessarily disputing the validity of a claim. Instead, it is acknowledging uncertainty and asking the court to resolve competing claims. Understanding this distinction can help claimants navigate what may otherwise feel like a denial or delay in benefits payment.
5. Legal Representation Strengthens Outcomes: Because ERISA procedures and state law interactions are complex, claimants represented by knowledgeable counsel are more likely to protect their rights and recover benefits efficiently. Legal advocacy can make the difference between a timely, favorable resolution and a forfeited or prolonged claim.

Ultimately, the court’s opinion ensures that the proceeds of Johnson’s life insurance policy will go to the proper beneficiary—Stacy, representing the estate of the victim—rather than to the individual responsible for his death. The decision exemplifies how federal courts can reconcile ERISA’s procedural mechanisms with state law doctrines designed to promote justice and equity.