In re Estate of Mahoney
220 A.2d 475 (1966)

Facts:
Charlotte Mahoney was convicted of manslaughter for the death of her husband, Howard. Howard left no issue and was survived by his mother and father. His estate amounted to $3,885.89.

History:
The Probate Court awarded Howard’s estate to his mother and father in equal shares, and didn’t involve Charlotte at all.

  • Charlotte appealed.

Issue:
Whether a widow convicted of manslaughter in connection with the death of her husband may inherit from his estate.

Holding:
A slayer who becomes entitled to the property of his victim as result of murder or voluntary manslaughter acquires legal title to property but holds it as a constructive trustee for the benefit of heirs or next of kin of decedent.

Reasoning:
It is the intent to kill, which when accomplished, leads to the profit of the slayer that brings into play the constructive trust to prevent the unjust enrichment of the slayer by reason of his intentional killing.

  • Thus, involuntary manslaughter wouldn’t prevent an individual from receiving property he or she was entitled to.
  • The same goes for someone who has killed while insane.

Side Note: The case was reversed, but on procedural / jurisdictional grounds:

  • The Probate Court was bound to follow the statutes of descent and distribution and decree the estate to the widow.
  •  Because the Probate Court does not have jurisdiction to hold the widow as a constructive trustee, the parents must then make application to the Court of Chancery.