Can a Killer Collect Life Insurance?
A Shocking ERISA Case and the Slayer Rule Explained
What happens when the named beneficiary of a life insurance policy murders the insured—and then claims the money?
Most people assume the answer is obvious. Surely the law would never allow a killer to profit from their crime.
But when life insurance is governed by ERISA, the federal statute that controls most employer-provided benefit plans, the answer is not always straightforward. ERISA has powerful preemption rules, strict requirements to follow plan documents, and a long history of overriding state laws.
In a chilling case decided by the U.S. Court of Appeals for the Sixth Circuit in 2024, a convicted murderer argued that ERISA required the insurer to pay him anyway—because he was the named beneficiary on his mother’s employer-provided life insurance plan.
The facts were horrific. The legal argument was bold. And the court’s decision now stands as one of the most important modern rulings on the “slayer rule” in ERISA life insurance cases. This is the story of Standard Insurance Co. v. Guy—and what it means for families fighting over life insurance after a crime.
The Case That Shocked the Court
In late 2016, Joel Michael Guy, Jr. murdered both of his parents in Tennessee. The killings were not impulsive. They were planned, brutal, and financially motivated. After the murders, Guy dismembered their bodies and attempted to cover up the crime.
A jury later convicted him of two counts of first-degree premeditated murder, among other offenses. His convictions were upheld on appeal. There was no dispute about what happened—or why.
But soon a different legal battle began.Guy’s mother had participated in employer-provided life insurance and accidental death & dismemberment (AD&D) plans, governed by the Employee Retirement Income Security Act of 1974 (ERISA). She had named her son as a beneficiary. Despite murdering her, Guy demanded the insurance proceeds.
His argument?
ERISA required it.
Why ERISA Complicates Life Insurance Disputes
To understand why this case mattered, you need to understand ERISA.
ERISA governs most group life insurance policies provided through employment. Unlike individual life insurance policies, ERISA plans are controlled by federal law, not state law. ERISA also includes a sweeping preemption provision, which overrides many state statutes—even ones that seem fundamental.
ERISA also requires plan administrators to follow the written plan documents when paying benefits. Courts often describe this as a “bright-line rule”: pay the named beneficiary listed in the plan.
Guy relied heavily on this principle. He argued:
He was the named beneficiary
The plan documents did not contain a “slayer clause”
ERISA requires administrators to follow the plan documents
Therefore, the insurer was legally required to pay him
If accepted, that argument would have forced insurers to pay murderers—unless every ERISA plan explicitly included a slayer provision.
That is why this case mattered far beyond its disturbing facts.
The Timeline of Events
2016: The Murders
Around Thanksgiving 2016, Joel Guy murdered his mother and father. Evidence showed his motive was financial gain, including access to insurance proceeds.
Criminal Trial and Conviction
A Tennessee jury convicted Guy of:
Two counts of first-degree premeditated murder
Two counts of felony murder
Two counts of abuse of a corpse
His convictions were affirmed on appeal and became final.
The Insurance Claims
Guy’s mother had:
Employer-provided life insurance
Employer-provided AD&D coverage
Dependent coverage insuring Guy’s father
Guy was listed as a beneficiary under the plans.
The Insurer Files an Interpleader
Faced with competing claims from family members, Standard Insurance Company filed an interpleader action, asking the court to decide who was legally entitled to the benefits.
Family Members Challenge Guy’s Claim
Other relatives argued that Guy was barred from recovery under:
Federal common law, which has long prohibited killers from profiting from their crimes
Guy’s Defense
Guy argued:
ERISA preempted Tennessee’s slayer statute
Federal law required strict adherence to the plan documents
Because the plan named him, he had to be paid
The district court rejected his arguments. Guy appealed.
The Legal Question Before the Sixth Circuit
The Sixth Circuit framed the issue clearly:
Who should receive ERISA life insurance benefits when the named beneficiary intentionally murders the insured?
To answer that question, the court had to decide:
Does ERISA preempt state slayer statutes?
If so, does ERISA itself require payment to the murderer?
If ERISA is silent, can courts apply federal common law?
The Slayer Rule: A Deeply Rooted Legal Principle
Long before ERISA existed, courts followed a simple rule:
A person may not profit from their own wrongdoing.
This principle—known as the slayer rule—has existed for centuries. Courts have applied it to:
Wills and estates
Trusts
Life insurance policies
As far back as the 1800s, courts held that allowing a murderer to collect life insurance would be “a reproach to the jurisprudence of the country.”
By the time Congress enacted ERISA in 1974, the slayer rule was universally recognized in American law.
What the Court Decided
1. ERISA Does Not Address the Slayer Scenario
The Sixth Circuit first examined ERISA’s text. It found that ERISA says nothing about what happens when a beneficiary murders the insured.
ERISA requires plans to follow written documents—but it does not explicitly say that this rule applies even in cases of murder.
The court emphasized that ERISA’s “pay the named beneficiary” rule is not absolute.
2. Supreme Court Precedent Leaves Room for Exceptions
The court distinguished prior Supreme Court cases that emphasized following plan documents. Those cases involved:
Divorce
Waivers
Administrative clarity
They did not involve murder.
In fact, the Supreme Court has expressly stated that it has never decided whether ERISA overrides the slayer rule—leaving the issue open.
3. If ERISA Is Silent, Courts May Apply Federal Common Law
When ERISA leaves a gap, courts are allowed to develop federal common law to fill it.
This is not done lightly—but it is appropriate where:
ERISA is silent
A long-standing common-law principle exists
Applying that principle is consistent with ERISA’s purpose
4. Federal Common Law Includes the Slayer Rule
The court held that the slayer rule is:
Ancient
Universal
Deeply embedded in American law
Fully compatible with ERISA’s goal of protecting participants and beneficiaries
There was no evidence Congress intended ERISA to abolish this rule or incentivize murder for financial gain.
5. The Result: The Murderer Gets Nothing
Because Guy was convicted of intentional, premeditated murder:
He was disqualified from receiving any life insurance benefits
The proceeds passed to alternate beneficiaries under the plan
ERISA did not save him
Federal law did not protect him
The Sixth Circuit affirmed the lower court’s decision in full.
Why This Case Matters for Families
This case sends a powerful message:
ERISA does not create a loophole for killers
Insurers are not required to pay murderers
Courts will apply the slayer rule even in ERISA-governed plans
But it also highlights something else: these cases are not simple.
ERISA disputes involve:
Federal jurisdiction
Preemption arguments
Complex procedural rules
Interpleader actions
Strict deadlines and evidentiary requirements
Families often assume “common sense” will prevail. In reality, legal strategy matters enormously.
What If You Are Facing a Life Insurance Dispute After a Crime?
If a loved one has died and there are questions about:
A beneficiary’s conduct
Undue influence
Fraud
Criminal acts
ERISA-governed life insurance
You should not assume the insurer will automatically “do the right thing.”
Insurers often file interpleader actions and let families fight it out in federal court. Without experienced legal guidance, rightful beneficiaries can lose everything.
Frequently Asked Questions About the Slayer Rule and Life Insurance
Can a murderer collect life insurance benefits?
No. A person who intentionally and feloniously kills the insured is barred from receiving life insurance benefits. This principle—known as the slayer rule—prevents anyone from profiting from their own wrongdoing. Courts apply this rule even when the killer is the named beneficiary.
Does ERISA allow a killer to collect life insurance if they are the named beneficiary?
No. While ERISA generally requires plan administrators to follow plan documents, federal courts have held that this rule is not absolute. When a beneficiary murders the insured, courts apply the slayer rule under federal common law, and the killer is disqualified from receiving benefits.
What is the slayer rule in life insurance law?
The slayer rule is a long-standing legal doctrine that prevents a person from inheriting or receiving insurance proceeds if they intentionally caused the insured’s death. The rule applies to wills, trusts, estates, and life insurance policies, including employer-provided plans governed by ERISA.
Does ERISA preempt state slayer statutes?
Courts have not issued a single universal rule, but many federal courts hold that even if ERISA preempts state slayer statutes, federal common law independently applies the slayer rule. The outcome is the same: a murderer cannot collect life insurance benefits.
What happens to life insurance proceeds if the beneficiary is disqualified?
If the named beneficiary is disqualified under the slayer rule, the life insurance proceeds typically pass to:
Alternate beneficiaries named in the policy, or
The insured’s estate, depending on the policy terms and governing law.
Does the slayer rule apply only after a criminal conviction?
Not always. While a criminal conviction makes the application of the slayer rule straightforward, some courts may apply the rule based on civil findings that the beneficiary intentionally caused the insured’s death, even without a criminal conviction.
Does the slayer rule apply to accidental deaths or self-defense?
Generally, no. The slayer rule applies when a beneficiary intentionally and feloniously causes the insured’s death. Courts typically do not apply the rule to truly accidental deaths or lawful acts of self-defense. In some cases, legal insanity may also prevent application of the rule. However, courts may independently evaluate the facts in civil proceedings, even without a criminal conviction.
Can a life insurance company refuse to pay when a beneficiary is accused of murder?
Yes. Insurers often file an interpleader action in federal court when there is uncertainty about who should receive the proceeds. This allows the court to decide entitlement and protects the insurer from paying the wrong party.
What if the life insurance policy does not mention the slayer rule?
Even if the policy is silent, courts will still apply the slayer rule. The doctrine exists independently of policy language and is enforced through state law or federal common law, especially in ERISA cases.
What should families do if a beneficiary is involved in the insured’s death?
Families should consult a life insurance lawyer immediately. These cases often involve ERISA, federal court procedures, strict deadlines, and complex legal standards. Early legal action can preserve evidence and prevent improper payment of benefits.
Do I need an ERISA lawyer for a life insurance beneficiary dispute?
If the policy is employer-provided, yes. ERISA cases follow different rules than regular insurance claims. An experienced ERISA life insurance lawyer can challenge wrongful beneficiary claims, handle interpleader actions, and protect your right to the proceeds.
Talk to a Life Insurance Lawyer Who Handles ERISA Cases
Life insurance disputes—especially those involving ERISA—are not ordinary insurance claims. They require a lawyer who understands:
Federal ERISA law
Beneficiary disputes
Slayer rule cases
Interpleader litigation
Appeals and complex motion practice
If you are dealing with a denied life insurance claim, a beneficiary dispute, or an ERISA life insurance issue, experienced legal representation can make the difference between recovery and loss.
Call (888) 510-2212 for a free case evaluation.
If you believe life insurance benefits are being wrongfully withheld—or paid to the wrong person—contact me for a confidential consultation.
I help families nationwide challenge denied and delayed life insurance claims and fight unfair ERISA decisions.
Contact me today to protect your rights and your recovery.
