Laborers’ Pension Fund v. Miscevic

In instant interpleader action seeking determination of ownership of union pension fund’s death benefits, Dist. Ct. did not err in finding that wife of deceased union member could not receive said benefits under circumstances where wife was found not guilty by reason of insanity in murder of union member. Illinois slayer statute precludes person who “intentionally and unjustifiably causes death of another” from recovering property by reason of said person’s death, and court in Doughtery, 934 N.E.2d 16, found that said statute applied to individuals who were found to be criminally insane, but nevertheless were cognizant that he or she was killing person. Moreover, wife of union member fit Doughtery holding, since trial judge in wife’s criminal case made explicit finding that wife intended to murder union member without justification despite concluding that wife was not guilty of murder by reason of insanity. Ct. also rejected wife’s claim that slayer statute was preempted by ERISA.