Essay: Riggs v Palmer – interpretation

The case of Riggs v Palmer raised many questions as to how the laws should be interpreted. In brief, Mrs. Riggs, Mrs. Preston and Elmer Palmer were beneficiaries for the will of the testator Francis B. Palmer. Mrs. Riggs and Mrs. Preston were the two daughters who accused Elmer Palmer, the grandson of Francis Palmer for obtaining the contents of the will by unethical and immoral practice. Elmer Palmer, who was also a minor, poisoned his grandfather to gain immediate access to the property he would receive from the will. The appellants argued that Elmer Palmer should be disallowed from obtaining the contents of the will with such immoral practice and his privilege from will be revoked. However, according to the definite interpretation of the statute, the defendant Elmer Palmer would still be the rightful owner of his part of the will and despite murdering his grandfather, he will still gain access to his estate. The focus of this essay is to analyze the decision made by the judges on the case of Riggs v. Palmer, and what challenges arose during the decision making process. This essay will utilize the theories of Natural Law and Positivism to demonstrate the decision-making process of the majority judges in favor of the plaintiffs, and also the judges for the defendant.
 
The majority decision was in favor of the plaintiffs and against the defendant. The judge in favor of the majority decision was Judge Earl, and he wrote that despite the governing statute of the will be in favor of the defendant, the resolution of the statute was not well-defined. According to Judge Earl, in a particular case such as this, the purpose of the law must be examined before any decision can be concluded. When lawmakers initially write a law, they do not keep the intention in mind, as a result, it is the judge’s duty to determine how the law must be interpreted varying on the situation presented in the case. The reason behind this method is to allow judges to make the best decision possible and avoid unreasonable and ludicrous penalties. Judge Earl clarifies that the lawmakers would not have intentionally allowed that Elmer Palmer murder Francis Palmer to obtain his will through the statute. Judge Earl continues by stating that laws within the western common law states are governed accordingly by fundamental maxims of common law. The main purpose of these maxims is to severe the unsatisfactory writing in the bill. The fundamental concern risen is whether a murder be able to benefit and profit from their crime? Therefore, Judge Earl argues that in accordance with the theory of Natural law, an individual must not inherit property or any other benefits from a will of whom they have inflicted death. According to the theory of Natural Law, Elmer Palmer obtains the will through the immoral act of murder and should not be entitled to his grandfather’s estate.

Natural Law Theory was the core concept behind the majority decision by the court because the statute was not intended to be deployed in this sense, therefore the decision was more in favor of the purpose and morality of the statute. According to Natural Law, decision making must have a strong link with morality and good virtue. All laws that are not intended to correspond with the Natural Law are unjust laws. Therefore, morality and positive virtue lead to the birth of a strong legal rule. In this particular case, despite the statutes clearing stating that the defendant has all the rights to obtain the will, there is no such aspect in terms of morality which allows the murderer to take advantage of their crimes. The majority decision relied on the morality of the law and its fundamental maxims.
On the other hand, there was only one dissenting judge in this case. Judge Gary, states that the ruling should be in correspondence with the rules of law and there should be no need to participate in establishing new meanings of law or attempting to impose further punishment for the committed crime. Judge Gary argues that the defendant does not require to be punished more than just serving his sentence for second degree murder. He states that matters such as these should be left to the legislature and following the statutes as they are written is the best way for decision making. In addition, he points out that it is written in the statute that no written will should be revoked or altered. Any changes must be made strictly within the language of the statute otherwise they change the interpretation of the written meaning of the statute.

The dissenting judge comprises his arguments using Legal Positivism. His arguments are based on the rigid rules of law and he claims that there is no connection between legality and morality. Judge Gary believes that legal decisions should be made with a strict logical system and without the influence of social considerations. Morality can not be defined by rationality unlike factual statements and proofs. According to Judge Gary, he does not see any sort of evidence that would void Elmer Palmer’s legal right to obtain the estate from the will. There was no written law within the legislature or statute that should punish the defendant further by revoking his rights to the will. If the majority of the court advocates the appellant’s argument, then they have fundamentally altered the will of the testator. Therefore, by doing so, the majority of the court has added on further punishment for the defendant by rescinding his share of the will.

In conclusion, although the dissenting judge states strong arguments that have legitimacy, it is not enough to win the majority decision on the court. In the modern society we live in today, the majority decision in favor of the appellants is more coherent and realistic. In the case of Riggs vs Palmer, the judges were very clear about their own point of views on how they interpreted the case and how they wanted the outcome to be like. With Judge Earl stating how the law cannot always be followed by its literal meaning and Judge Gray describing the opposite with viewing the law the exact way as it is stated. It was concluded that the majority sided with Judge Earl whom the plaintiffs were being defended on resulted in a win for them and justice for their late grandfather. The courts should still practice strict interpretation of the law and statues but in cases such as this one, where morality is in question, then there should be room for some flexibility for determining the decision. The law was examined clearly in accordance with this case which later resulted in making a decision that would change the whole case in favor of the plaintiffs. Courts need to continue to interpret laws in a manner that suits the particular case because law makers did not keep in mind exactly which scenarios a fundamental law may be in question. Every case that is brought to the courts is different from the other and in order for judges to be able to make a rational and precise decision, the laws related must be viewed in sync with the case.

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