The Background to Riggs v. Palmer

Abstract

The decision of the New York Court of Appeals in Riggs v. Palmer (1889) is remarkable for the mass of discussion about a variety of fundamental issues that it has generated. Elmer Palmer was convicted of murdering his grandfather Francis, and the court refused to let him inherit under Francis’s will despite the absence of any explicit statutory grounds for voiding the legacy. An exercise in legal archaeology uncovering details that are stated only obliquely (or not at all) in the majority and dissenting opinions corrects a number of errors often made about the case. More speculatively, it suggests a new explanation of the result, one supported by a review of similar cases in other states in the same era and of the composition of the Court of Appeals in 1889: that the decision in Riggs is best understood as an ad hominem one, provoked by the unusually light punishment that Elmer had received for his crime and rationalized by an appeal to legal principles. If it was, much of what has been written about the decision and its significance is called into question.