Riggs v. Palmer
|Riggs v Palmer|
|Court||Court of Appeals of New York|
|Citation(s)||115 NY 506 (1889)|
|Robert Earl J|
|Wills, killing, construction|
Riggs v. Palmer, 115 N.Y. 506 (1889), is an important New York state civil court case, in which the Court of Appeals of New York issued an 1889 opinion. Riggs was an example of the judiciary using the "social purpose" rule of statutory construction, the process of interpreting and applying legislation.
In Riggs, a probate suit, the plaintiffs, Mrs. Riggs and Mrs. Preston, sought to invalidate the will of their father Francis B. Palmer; testated on August 13, 1880. The defendant in the case was Elmer E. Palmer, grandson to the testator. The will gave small legacies to two of the daughters, Mrs. Preston and Mrs. Riggs, and the bulk of the estate to Elmer Palmer to be cared for by his mother, Susan Palmer, the widow of a dead son of the testator, until he became of legal age.
Knowing that he was to be the recipient of his grandfather's large estate, Elmer, fearing that his grandfather might change the will, murdered his grandfather by poisoning him. The plaintiffs argued that by allowing the will to be executed Elmer would be profiting from his crime. While a criminal law existed to punish Elmer for the murder, there was no statute under either probate or criminal law that invalidated his claim to the estate based on his role in the murder.
Judge Robert Earl (in office 1870 and 1875–1894) wrote the majority opinion for the court, which ruled in favor of the plaintiffs. The court reasoned that tenets of universal law and maxims would be violated by allowing Elmer to profit from his crime. The court held that the legislature could not be reasonably expected to address all contingencies in crafting laws and that, had they reason to suspect one might behave in the manner Elmer did, they certainly would have addressed that situation.
Judge Earl, in an analogy to a similar case, wrote: "The principle which lies at the bottom of the maxim, volenti non fit injuria ['to a willing person, no injury be done'], should be applied to such a case, and a widow should not, for the purpose of acquiring, as such, property rights, be permitted to allege a widowhood which she has wickedly and intentionally created."
Judge John Clinton Gray (in office 1888–1913) dissented. He argued that the criminal law established punishment for the murder of Francis Palmer. For the court to deny the estate to Elmer was to, in effect, add significant further punishment to what Elmer received under the criminal statute, something the court was not permitted to do without the express, written statute. The written statutes that existed did not sanction the action of the court and the court cannot simply create or imagine such statutes so as to obtain a morally pleasing result. Gray's view of literal interpretation of the statute was in contrast with the majority opinion which gave the legislators' intentions influence over the actual statutes in place.
Legal philosopher Ronald Dworkin uses Riggs in an argument against legal positivism, focusing on a version of positivism by H. L. A. Hart. As a leader of the philosophy of Legal Positivism, Hart argues that the decisions in this case should be based on existing law, which was silent on the issue at the time. Positivism holds that all legal decisions by courts are classified into one of two categories. Some are central to the legal rules at issue. In these cases, judges merely mechanically apply the rules which fall within their jurisdiction. The other category of decisions occupy the penumbra of legal rules, where the direction of the legal rule is unclear. In these cases, judges must decide which of the possible applications of the legal rules are best social policy and then apply the rule which is best.
Dworkin argues that Riggs has two features which contradict Hart's interpretation of the legal process. First, this case does not appear to lie at the edge of legal rules, instead it is very clearly central. Despite this, the majority did not apply the legal rule as required. Second, there appears to be a legitimate debate about what the law is, and not what the law should be, in this case. According to Dworkin, under most versions of legal positivism, Hart's included, there should rarely be debate about what counts as law.
In Taking Rights Seriously, Dworkin argues that this case shows that in addition to rules established in statutes, principles are also a component of law. These principles, while not binding in the same manner the rules can be, are sufficient to modify statutes as in Riggs. He argues that both the majority and the dissent use these legal principles -- "one cannot benefit from one's own wrongdoing" in the case of the majority and "one should not be punished beyond the ways specified in the statute" in the case of the dissent.
- "Hart, H.L.A. (1961). The Concept of Law. Oxford University Press. ISBN 0-19-876005-1.
- Dworkin, Ronald (1986). Law's Empire. Cambridge, MA: Belknap Press (Harvard University Press). ISBN 0-674-51836-5.
- Dworkin, Ronald (1977). ""The Model of Rules I"". Taking Rights Seriously. Cambridge, MA: Harvard University Press. ISBN 0-674-86710-6.