Law School Case Brief
Union Sec. Life Ins. Co. v. JJG-1994 - No. 1:10-CV-00369 (LEK/RFT) 2011 U.S. Dist. LEXIS 94767 (N.D.N.Y. Aug. 24, 2011)
The United States Court of Appeals for the Second Circuit (Second Circuit) has distinguished laws that are not preempted by the Employee Retirement Income Security Act (ERISA), 29 U.S.C.S. § 1001 et seq., as those of general application—often traditional exercises of state power or regulatory authority—whose effect on ERISA is incidental. It has been found that the New York slayer rule is not preempted by ERISA. This reasoning falls within the Second Circuit guidelines.
On January 24, 2008, Decedent was shot and killed in his home in New York. His older son, JJG-1994, was charged as an adult with second degree murder, and subsequently pled guilty to first degree manslaughter for the killing. At the time of the shooting, JJG-1994 was found to be acting under extreme emotional disturbance, but not out of self-defense. As part of the plea, JJG-1994 admitted to firing the shotgun at the decedent's head while he was lying on the couch. His case was handled in Family Court; at the time of the case, he was at a secure juvenile detention facility.
Decedent was a participant in his employer's Employee Retirement Income Security Act-regulated ("ERISA") group life insurance plan (the "Plan"). At the time of his death, Decedent's sole beneficiary was JJG-1994. Because of the nature of his death, Decedent's beneficiary is entitled to $10,000 in life insurance, as well as an additional $10,000 in accidental death benefits. Subsequent to his death, two claims for Decedent's benefits were filed on JJG-1994's behalf, and one claim was filed on behalf of JJG-2002. JJG-2002 contended that the New York common law rule prohibiting a killer from profiting from his crime applies here and was not preempted by ERISA. JJG-2002 filed this motion, seeking summary judgment.
Believing JJG-1994 to be ineligible to receive the benefits under New York's common law slayer rule, Plaintiff Union Security Life Insurance Company of New York was unsure of how to proceed and filed the present complaint for interpleader relief.
Is the New York slayer rule preempted by ERISA?
JJG-2002's motion for summary judgment was granted. The Court held that (1) ERISA did not preempt New York's slayer rule, (2) JJG-1994 was collaterally estopped from denying guilt in a civil case, (3) his age and emotional disturbance created no slayer rule exception, (4) a lack of codification did not make the rule inapplicable, and (5) New York law barred the benefits from passing to his heirs.
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