How have courts dealt with the issue of a beneficiary that had been murdered?

California, United States of America


The following excerpt is from State Farm Life Ins. Co. v. Pearce, 234 Cal.App.3d 1685, 286 Cal.Rptr. 267 (Cal. App. 1991):

In Beck v. West Coast Life Ins. Co. (1952) 38 Cal.2d 643, 647, 241 P.2d 544, the court awarded the life insurance proceeds to an alternate beneficiary (not related to the primary beneficiary who had murdered the insured) because such was the clear intent of the deceased. The literal wording of the beneficiary clause was such as to transfer to the unrelated friend the policy benefits in the event the insured's husband could not receive them. The reason for award of the policy benefits to the alternative beneficiary was not the predecease of the husband, which would have been expected by the insured based on the beneficiary designations. The husband was precluded from taking not because of his prior death, but because of the equitable doctrine . preventing one from benefiting from his own wrong. This unexpected cause for activating the alternative nomination in no way, however, invalidated it.

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