In the words of Yoda: Murder Does Not an ERISA Claim Pay

In Standard Ins. Co. v. Guy, No. 21-5562, __F.4th__, 2024 WL 3857926 (6th Cir. Aug. 19, 2024), an interpleader action involving the proceeds of ERISA-governed benefit plans, the Sixth Circuit considered the question of “whom should the plan administrator pay when the plan-designated beneficiary has intentionally murdered the plan participant?” The district court concluded that either ERISA does not preempt Tennessee’s slayer statute or that the federal common law prevents Defendant Joel Guy from benefiting from his murders. The Sixth Circuit affirmed the district court and held that Guy cannot recover under Tennessee law nor federal common law.

As recounted by the court, around Thanksgiving in 2016, Guy murdered his mother and father, and then dismembered their remains. A Tennessee jury found Guy guilty of two counts of first degree premeditated murder, two counts of felony murder, and two counts of abuse of a corpse. “The details are horrific, and Guy’s motivation was expressly financial.” Guy’s mother was a participant in life and accidental death & dismemberment insurance plans through her employer. Guy’s father was insured under the dependent provisions of these plans. Guy’s mother named Guy and Guy’s father as the plan beneficiaries. Guy murdered his mother and then sought to collect the proceeds of her benefit plans. If Guy is disqualified to receive the death benefits, they would go to his half-sisters and his aunt and uncle. Standard Insurance Company filed an interpleader action to determine entitled to benefits. The district court granted the family members’ motions for summary judgment and Guy appealed pro se. The Sixth Circuit appointed counsel to represent Guy on appeal.

To answer the question raised by this case, the court first considered the source of law that provides the rule of decision. The court noted that under Tennessee law, Tenn. Code Ann. § 31-1-106(c)(1)(A), Guy is not entitled to the proceeds of his mother’s policies. But the court also noted that federal, rather than state law, governs most ERISA plan issues. Typically, in matters involving beneficiary designations for ERISA plans, courts do not apply state law. In Egelhoff v. Egelhoff, 532 U.S. 141, 144, 146, 121 S.Ct. 1322, 149 L.Ed.2d 264 (2001), the U.S. Supreme Court left open the question whether state slayer statutes might provide the rule of decision in a case such as this. However, the Sixth Circuit declined to resolve the preemption issue left open in Egelhoff because Guy cannot recover under federal law.

Assuming without deciding that ERISA preempts Tennessee’s slayer statute, the court looked to federal law to determine whom the plan administrator should pay. ERISA’s text does not specifically address the slayer question and the plan documents in this case are silent as to how to handle a slayer scenario. The court distinguished this case from Kennedy v. Plan Administrator for DuPont Savings & Investment Plan, 555 U.S. 285, 129 S.Ct. 865, 172 L.Ed.2d 662 (2009) (awarding plan benefits to ex-wife who was named beneficiary despite her common-law waiver of any interest in the benefits) and the “pay-the-designated-beneficiary rule” that came from that decision. This rule is not absolute and is subject to some exceptions. In Tinsley v. Gen. Motors Corp., 227 F.3d 700, 704 (6th Cir. 2000), the court held that in cases of forgery, undue influence, or where the beneficiary designation is otherwise improperly procured, an administrator must look beyond the beneficiary designation itself to determine whom to pay. The court found that this case is more like the doctrines of undue influence and fraud addressed in Tinsley than the divorce and waiver issue in Kennedy. In Kennedy, the parties had the ability to change the beneficiary designation after the divorce. Here, Guy’s mother had no idea her son would murder and dismember her; certainly, she would not have made him the beneficiary of her life insurance policy had she known what was to occur.

Because ERISA does not provide the answer, the court looks to federal common law for a rule of decision. It is well recognized, including by the Supreme Court, the slayer principle that one cannot recover insurance money payable on a death of the party he had feloniously taken. The court cited to early academic descriptions of the common-law slayer rule and that courts are in agreement that a beneficiary cannot maintain an action for insurance proceeds after having murdered the insured. The court found that Guy’s conduct falls within the scope of the rule and does not come under any narrow exceptions of acting in self-defense or by accident. Guy’s conviction of premeditated murder is final. His murderous act disqualifies him from the proceeds of his mother’s ERISA-governed policies.