Mutual Life Insurance Co. of New York v. Hillmon
145 U.S. 285, 12 S. Ct. 909, 36 L. Ed. 706 (1892)

  • Hillmon was a cattle rancher from Kansas.  He was traveling with a guy named Brown looking for a good site to build a new cattle ranch.
  • Brown came out of the prairie in Colorado and claimed that he had accidentally shot and killed Hillmon.
    • A body was found in a creek where Brown said it would be.
  • Hillmon’s wife claimed that it was his body and asked the insurance company for her insurance money.
  • Mutual Life countered that the body was that of another man, Walters, who had left Iowa and disappeared in Kansas.
    • Mutual Life was suspicious because Hillmon recently took out three massive insurance policies on himself that he couldn’t afford.
    • Mutual argued that Hillmon and Brown had conspired to murder Walters and use his body to collect the insurance money.
      • The body was dressed in Hillmon’s clothes and carrying Hillmon’s diary.
  • Hillmon’s wife sued the insurance companies to get her money.
  • At trial, Mutual Life attempted to introduce letters from Walters just before he disappeared saying that he was going with Hillmon to Colorado.
    • Mrs. Hillmon objected on the grounds that the letters were hearsay.
    • Mutual Life argued that under the common law, statements made in the present state of mind are admissible as an exception to hearsay.
  • The Trial Judge rejected the letters.
  • The Trial Court found for Hillmon.  Mutual Life appealed.
  • The US Supreme Court reversed and ordered a new trial.
    • The US Supreme Court looked to the common law and found that evidence of intention is an exception to hearsay.
      • The Court found that the letters could not used to prove that Walters did go to Colorado with Hillmon, but they could be used to show that Walters intended to go to Colorado with Hillmon.
      • “Wherever the bodily or mental feelings of an individual are material to be proved, the usual expressions of such feelings are original and competent evidence.”
  • This case established “the Hillmon Doctrine” which says that, the state of mind of the declarant can be used inferentially to prove other matters that are in issue.
    • “When the performance of a particular act by an individual is an issue in a care, his intention to perform that act may be shown. From that intention, the factfinder may draw the inference that the person carried out his intention and performed the act.”
    • Basically, if a person says that they are going to do an act, then that statement is relevant evidence that can be used to help prove that they actually did the act.
      • It isn’t conclusive proof, but it can help.
  • Interestingly, there is evidence that the insurance companies forged Walter’s letter.  If so, a whole doctrine of evidence was based on a lie.