In re Estate of Haber

Summary

The court grants summary judgment against all claims by Betty Lou Haber to property from her deceased husband’s estate after her conviction for his murder. It holds that Florida’s murderer’s statute bars her inheritance, dower, homestead, and will-based claims, and that equitable principles bar her contractual claims under an ante-nuptial agreement. The court also relies on the criminal conviction, of which it took judicial notice, and concludes that the purported unilateral amendment to the agreement cannot support her claims.

Holdings

1. A person convicted of murdering a decedent is barred by Florida's murder statute from inheriting from the decedent or taking as a legatee or devisee, and the statute also bars Haber's dower, homestead life-estate, and will-based life-estate claims because those rights arise from Florida's probate and succession laws and depend on an inheritable interest or surviving-spouse status.
2. The equitable maxim that no wrongdoer should profit from his or her own wrong bars Haber's claims for benefits under the ante-nuptial agreement because she feloniously caused the condition involving the continuation of the marriage until Albert's death.
3. Even assuming the purported amendment to the ante-nuptial agreement was valid, the equitable rule against profiting from one's own wrong would bar Haber's asserted rights under it.
4. Judicial notice of the affirmed criminal conviction dispensed with the need to relitigate Haber's guilt in the probate proceeding.

Questions Presented

1. Whether an affirmed conviction for murdering a decedent bars the murderer from asserting dower, homestead, will-based life-estate, and other probate-law rights in the decedent's estate.
2. Whether the equitable principle that no person may profit from his or her own wrong bars a murderer's claims founded on an ante-nuptial agreement.
3. Whether judicial notice of the criminal conviction eliminates the need to relitigate the murderer's guilt in the probate proceeding.
4. Whether the personal representative was entitled to summary judgment on all of Haber's claims.

Disposition

other