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Keywords

pleatrustcommon law

appealtrialpleabeyond a reasonable doubtcommon law

Related Cases

Shrader v. Equitable Life Assur. Soc. of U.S., 20 Ohio St.3d 41, 485 N.E.2d 1031, 20 O.B.R. 343

Facts

John Shrader sought to recover life insurance proceeds after the death of his wife, Jean Shrader, who was found strangled. Following allegations from Jean's father that John had intentionally killed her, the insurance company deposited the policy proceeds with the court. John was held in civil contempt for refusing to answer questions regarding the circumstances of her death, and after further proceedings, the court ruled against him, awarding the proceeds to Jean's father's charitable trust.

Husband of strangled decedent sought to recover life insurance proceeds payable upon his wife's death. After decedent's father, the policy's secondary beneficiary, alleged that decedent's husband had intentionally and feloniously killed his wife, the insurer, in a defensive interpleader posture, deposited the policy proceeds with the court.

Issue

Whether the identity of a person who intentionally and feloniously caused the death of another can be established in a civil proceeding to prevent the wrongdoer from receiving the proceeds of the deceased's life insurance policy.

The first issue in this case is whether R.C. 2105.19, dealing with persons prohibited from benefiting from the death of another, is applicable in this case.

Rule

The common law principle that no one should profit from their own wrongful conduct applies, allowing a civil court to determine if a beneficiary intentionally and feloniously caused the death of the insured.

The well-established policy of the common law is that no one should be allowed to profit from his own wrongful conduct.

Analysis

The court applied the common law principle that a beneficiary who intentionally and feloniously causes the death of the insured cannot recover insurance proceeds. It determined that the civil court could adjudicate the issue of identity and responsibility for the death, even in the absence of a criminal conviction, thereby allowing the secondary beneficiary to challenge the primary beneficiary's claim.

This case then is like any other civil case. The trial court applied the law to the facts, granted judgment for the Wolfords, on their counterclaim, and determined that Shrader was not entitled to the insurance proceeds both because he had failed to prove his claim and because he had unlawfully terminated the life of his wife.

Conclusion

The Supreme Court reversed the appellate court's decision and reinstated the judgment of the Common Pleas Court, affirming that John Shrader was not entitled to the insurance proceeds due to the allegations against him.

The judgment of the court of appeals is hereby reversed and the final judgment of the court of common pleas is hereby reinstated.

Who won?

The decedent's father prevailed in the case, as the court ruled that John Shrader could not receive the life insurance proceeds due to the allegations of his involvement in Jean's death.

The appellate court in this case took the position that: 'Public policy supports the proposition that the identity of a murderer be proved beyond a reasonable doubt in available criminal proceedings rather than by a lesser degree of proof in a civil proceeding.'

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Micale v. Bank One N.A. (Chicago), 382 F.Supp.2d 1207

In re Tompkins’ Estate, nan

Walker v. Lawson, 526 N.E.2d 968

Kelly v. Lindenau, 223 So.3d 1074, 42 Fla. L. Weekly D1133

Bank One of Milford, N.A. v. Bardes, 25 Ohio St.3d 296, 496 N.E.2d 475, 25 O.B.R. 346