Riggs v. Palmer
Citation: 115 N.Y. 506 (New York Court of Appeals, 1889)
Facts
Elmer Palmer, fearing his grandfather Francis Palmer would revoke a will leaving Elmer a large inheritance, murdered his grandfather. Elmer claimed he was nonetheless entitled to the inheritance under the will, which was validly executed under New York’s statute of wills. The statute said nothing about forfeiture for murder. The other legatees (Francis’s daughters) sought to bar Elmer from inheriting.
Issue
Can a murderer inherit under a validly executed will when the governing statute of wills contains no forfeiture provision for homicide?
Holding
The New York Court of Appeals (4–3) held that Elmer could not inherit. Even though the statute of wills was silent on the issue, courts may construe statutes in light of fundamental principles of law and equity — including the maxim that no one shall be permitted to profit by his own wrong.
Rule
Statutes must be read in light of background principles of law and equity. Where a literal application of statutory text would produce results that violate fundamental legal maxims (here, that no one may profit from his own wrong), courts may construe the statute to avoid that result. This is sometimes called the equitable interpretation canon or the absurdity doctrine.
Significance
Riggs is a canonical case in jurisprudence and statutory interpretation. It raises core questions about whether judges interpret or make law, whether moral principles can supplement enacted text, and what role background common-law principles play in statutory construction. The case is frequently paired with H.L.A. Hart and Lon Fuller’s debate about law and morality, and with Dworkin’s theory of legal principles vs. rules. In legislation courses, it illustrates the limits of textualism and the role of equitable canons.