An Analysis of Riggs v. Palmer Case

An Analysis of Riggs v. Palmer Case

With a view of demonstrating knowledge attained concerning philosophy law, this essay will be a critical analysis of the Riggs v. Palmer case for the consenting or majority judge’s decision, Early J and Danforth J in favor of the Natural Law Theory, and which is conversely against the dissenting judge’s, Gray J’s decision which is based upon legal positivism theory.

Facts:

In this case, the appellants are Mrs. Palmer and Mrs. Riggs who were hoping to exclude Elmer E. Palmer, the defendant, from the Mr. Francis B. Palmer’s, the testator who as well doubles up as their father, will. In the will, the testator offers small legacies to both Mrs. Palmer and Mrs. Riggs, and the rest of his estate to Grandson Elmer Palmer, who is his grandson, and who at the time of drawing of the will was still a minor. However, the will was binding if only he would die while Elmer was still under age and unmarried. Elmer being aware of the contents of the will, and with the idealization that his grandfather would manifest an intention to change the will, and in the same light with the intention of “Speedy enjoyment and immediate possession of his property,” Elmer poisoned Francis, his grandfather. Gathering from this action, the appellants started arguing that Mr. Elmer should be denied the privilege as provided for by his grandfather. However, Elmer, the defendant, was still seeking for his privileges as provided by the will to remain as his grandfather was now deceased. Despite common law providing a different provision, upon a strict interpretation of the law, the will still favor Mr. Elmer.

Majority Decision:

Judge Earl, in favor of Mrs. Palmer, and Mrs. Riggs, the plaintiffs, wrote the majority decision, against Mr. Elmer, the defendant. From Judge Earl’s writings, although the statue governing the implementation of the will base on its requirement and composition favors Mr. Elmer, the purpose of writing the statue is not to elaborate. As a result, the purpose for which the bill was written based upon must first be understood or established. As well, gathering from Judge Earl’s writings, the writers of the statues, as well, have not expressed the intention for writing the statue, and based on this the court is thrust with the role of making a rational conclusion of their intention which may as well be renowned as a “Rational Interpretation”. Gathering from the pertinence of “rational interpretation”, usually absurd or unintended consequences cannot be committed against “common reasons” given that the lawmakers did not have the intention that Mr. Elmer who at this juncture is a murderer ought to benefits from murdering Mr. Francis, and hence benefit under the pertains of his will as provided by the statue.

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Furthermore, the judge expounds that all laws as provided by western common law countries should be provided for by “fundamental maxims” of common law both in effect and operation. In their application, and in other instances with a view of nullifying the language postulated by a bill, maxims are universal. In the exposition of the above statement, “fundamental maxims” against fraud as provided by common law took a model in the case of “the New York Mutual Life Insurance Company v. Armstrong.” Similarly, with this case, Riggs v. Palmer, as there lacked certainty on the testator, Mr. Francis B Palmer, changing their mind or the legatee, Mr. Elmer, surviving the testator. As a result, fundamental maxims of common law must be applied. However, there should be the question if a murderer as provided by statue should they be allowed to profit from their victim’s crime.

Additionally, Judge Earl further argues that under the general principles of Natural Law and Justice, one is not allowed to take property either by will or inheritance from a benefactor or an ancestor whom they have killed. As a result, gathering that Elmer Palmer bequeathed property from Mr. Francis through the action of murdering him, he is therefore not entitled to the property. An example to match the above interpretation is the Owens v. Owens case where a wife murders their husband to gather accessory to his property to which the judge argued that through the principle of  “violent non fit injuria” the widow cannot be permitted to owe property through alleging widowhood through a wicked deed.  

As a result, Judge Earl reaches the conclusion that the opinion of the majority of the judges is that Elmer E. Palmer, the defendant, should be found guilty for the murder of the testator, Mr. Francis B. Palmer and as a result is not entitled to the estate as entitled as contained in the will. Instead, the plaintiffs, Mrs. Palmer, and Mrs. Riggs should thus be the true owners of the personal and real estate of Mr. Francis B. Palmer, the testator.

Dissenting judges:

In this case, Judge Gray was the only judge who was dissenting. According to arguments written by this judge, Gray points out that without precedent, and contrary to the decision of the majority judges, the court should be bound by the “rules of law” and as a result should not engage in making a new law and in the same light in imposition of another form of punishment for a similar crime committed by Mr. Elmer E. Palmer, defendant.

While further expounding his argument, Judge Gray further alludes that Mr. Elmer for his crime of murder, he is already serving time in a state reformatory. Furthermore, he writes that courts should be guaranteed by “rigid rules of law” as prescribed by the legislature on the conditions and directions that a testamentary disposition may either be altered or revoked. As a result, the arguments are matters such as these should only be handled by the legislature. However, in the absence of a direction by the legislature, then it should be argued that the appellant in the case, such as in this one, then the court should engage in “remedial justice.”

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Furthermore, the judge argues on the ground of explicit language as contained in the statue that may forbid changes as pointed out by “No will in writing, except in cases hereinafter mentioned, nor any part thereof shall be altered or revoked otherwise. Similarly, in the cases of Leaycraft v. Simmons and that of Gains v. Gains, Judge Gray furthermore points that the courts were strictly confined to the language of the statue, and in this case highlighted that the contrary would be “enlarging the statues.” As a result, the judge argues that for the Riggs v. Palmer Case, there is no evidence for which the claim by the defendant under the will where it should be voided as the laws should be deemed as “silent.” Furthermore, the judge argues that should the court uphold argument’s by the appellant; then the court is by virtue creating “another will for the testator,” something that is not prescribed by the laws. Moreover, the court will be held liable for creating another punishment for Mr. Elmer Palmer.

Connections between Judges Reasoning:

Gathering from the majority decision by the court, their justification can be thought to have been referenced from Natural law Theory given that the decision has been arrived based on the statue of “Unjust Law” and in approval of the Purpose and Morality of the statue.

Natural Law Theory prescribes that there is a relationship between law and morality. As a result, conforming to morality can be alluded as creating legality for the rule. Thus, any law that can be thought of as violating morality or natural law as an “Unjust Law.” As a result, in the case of Riggs v. Palmer case, then the statues that govern the will are rather clear, whilst there existed no relationship between morality and law for it allows for the legatee or the murderer to benefit from his action of murdering the testator. Therefore, the majority decision was more inclined to the morality of the law or “fundamental maxims” of the law.

Conversely, the dissenting judge relied more on positivist interpretation based on the consistency of his argument. They are gathering from their argument based on “rigid rules of law,” which shows the consistency of separation of the thesis, and which as well argues for a distinction between morality and legality.

Personal Opinion:

Whilst Judge Gray’s, the dissenting judge, the argument has some validity, the majority judge’s decision is consistent with societal realities. The above opinion is formed by the need to separate judicial processes and systems. Pertinently, however, is lacking disconnect between the realities of social normalities and the making of important decisions in cases similar to this one. Additionally, there should be a strict interpretation of laws in societies with a view of making a decision where basic moral norms conflict with laws.

Works Cited

• Riggs v. Palmer (October 8, 1889), 115 NY 506, Online: CHRT http://www.courts.state.ny.us/reporter/archives/riggs_palmer.html