The Slayer Rule: When a Beneficiary Is Accused of Causing the Death

The basic rule

The idea is old and simple: a person should not profit from killing someone. In 1889, New York’s highest court refused to let a grandson take under his grandfather’s will after he murdered him, even though nothing in the probate statutes said so expressly.¹ Today almost every state has a statute on the subject, and many follow the model in the Uniform Probate Code (UPC), section 2-803.

Under the UPC model, an individual who “feloniously and intentionally kills the decedent” forfeits benefits from the estate, and the killing revokes any revocable designation in the killer’s favor, including in a life insurance policy or other beneficiary designation. The killer is treated as having disclaimed, so the money passes to the next person in line.²

What must be proved

States answer three questions differently.

What kind of killing counts. UPC-based statutes cover a “felonious and intentional” killing. Georgia’s statute applies where the killing “would constitute murder or felony murder or voluntary manslaughter.”³ Utah uses a defined “disqualifying homicide” and excludes automobile homicide.⁴ Alaska’s statute disqualifies a beneficiary who “feloniously kills” the decedent and, unlike the uniform text, does not say the killing must be intentional. Accidents and negligence are generally outside these statutes.

Whether a conviction is required. In UPC states, a final conviction is conclusive, but a conviction is not required. Without one, the court decides “under the preponderance of evidence standard” whether the person “would be found criminally accountable for the felonious and intentional killing.”² Florida applies “the greater weight of the evidence.”⁵ Georgia requires “clear and convincing evidence” absent a conviction or guilty plea.³ Some states, such as Kansas, Kentucky, Oklahoma, and West Virginia, tie the bar to a conviction (see the table). Delaware’s statute is offense-based: it applies to a person who pleads guilty or no contest to, or is convicted of, listed homicide offenses, or whom a court finds responsible beyond a reasonable doubt.

Whether there is any flexibility. Utah lets a court decline to disinherit where that “would create a manifest injustice.”⁴

An open investigation is not evidence. The claimant who says a beneficiary is disqualified has to prove it. In Primerica v. Donley (N.D. Ala. 2019), minor contingent beneficiaries, through their guardian ad litem, opposed payment to the insured’s wife because the police investigation of his death was still open. The court noted that she had not been arrested, charged or convicted, and that the children offered no evidence tending to show her involvement: “because the children rely solely on the existence of an open investigation, and have not presented any credible evidence that [the primary beneficiary] was responsible for the insured’s murder,” her motion for summary judgment was granted under Alabama’s statute, Ala. Code § 43-8-253(c).⁶ The court cited a similar Ohio federal decision, Prudential Ins. Co. of America v. Blanton, 118 F. Supp. 3d 980 (N.D. Ohio 2015), in which a pending investigation and a “person of interest” label were not enough. See the decision summary.

When the criminal case decides it. Under Missouri’s statute, Mo. Rev. Stat. § 461.054(2), the killing may be established by a criminal conviction or guilty plea after the right of direct appeal is exhausted, or by a preponderance of the evidence in a civil proceeding.⁷ In First Unum Life Ins. Co. v. Marshall (W.D. Mo. 2024), an ERISA-governed employer plan named the insured’s domestic partner as primary beneficiary. He was charged in the insured’s death, and the insured’s mother, as representative of the estate, also claimed the benefit. The insurer filed its interpleader about eight months after the death. In the court’s summary of the parties’ position, “the outcome of the criminal case will likely be determinative” of which claimant was entitled to the money; the court agreed, staying all discovery pending the criminal case and requiring status reports every 60 days. It also noted that a registry deposit is generally not required for jurisdiction in a Rule 22 interpleader. The named beneficiary was convicted at his criminal trial, including of second-degree murder of the insured; the insurer then notified the court that, because of the conviction, he was giving up his interest. The court lifted the stay, and about five months after filing the parties dismissed the case by stipulation. According to the parties’ stipulation, he signed a disclaimer as a result of the conviction, and the insurer was to pay the full benefit, plus all accumulated interest, for the estate. No court decided the slayer question or whether Missouri law or federal law governed the ERISA plan.⁸ Read together with Donley: an open investigation alone did not defeat a named beneficiary’s claim, but a conviction ended one. Iowa’s slayer statute sets its own timetable: the civil case cannot go to trial until the criminal case ends.

Why insurers and banks stop payment

UPC-based statutes say a payor “is not liable for having made a payment” to the designated beneficiary before it “received written notice of a claimed forfeiture or revocation,” but “is liable for a payment made” after receiving such notice. The notice must be sent by registered or certified mail, return receipt requested, or served like a summons. Once it has notice, the payor may deposit the money with the probate court, and that deposit discharges it.²

So the moment an insurer receives a proper notice, paying the named beneficiary becomes risky for it. It usually holds the money until a court decides, or deposits it with a court through the statute’s procedure or an interpleader. Minnesota’s statute goes further for life insurance, requiring the insurer to withhold payment to all beneficiaries after written notice, pending a court order.¹⁰ The guide on how a claim freezes payment explains the wider pattern.

An insurer may also interplead when no one has been charged. In Hartford Life v. Jones-Atchison, an Oklahoma federal case, the insured died by homicide in January 2017, and his former spouse was the named beneficiary of his basic group life coverage. Police had not excluded her in their investigation; as of the court’s 2019 order no arrest had been made. As the Tenth Circuit described it, the insurer was unsure whether Oklahoma’s slayer statute, which bars a beneficiary convicted of the insured’s murder, would prevent payment to her, so it filed an interpleader in June 2017.¹¹ The claimants later settled that benefit, and no court decided the slayer question.¹²

Insurers also sometimes interplead when the death certificate lists the manner of death as undetermined and the beneficiary has not been charged. Colorado’s statute, for example, lets a court decide the slayer question in a civil case “[n]otwithstanding the status or disposition of a criminal proceeding,” so a competing claim can be made without any charge. Such a case can still resolve within months once the competing claim is withdrawn.¹³

Life insurance and federal programs

Some states have a separate insurance provision. Texas’ Insurance Code provides that a beneficiary “forfeits the beneficiary’s interest in the policy or contract if the beneficiary is a principal or an accomplice in wilfully bringing about the death of the insured,” and then sends the money to a contingent beneficiary or, if none, the insured’s nearest relative.¹⁴ Georgia has a separate insurance provision (O.C.G.A. § 33-25-13), referenced in the official commentary to its general statute.³

For employer plans governed by ERISA and federal programs such as FEGLI and SGLI, federal rules may affect how a state statute applies. UPC-based statutes anticipate this: if federal law preempts the statute, a person who receives the money “not for value” is personally liable to return it to the person who would have been entitled to it.⁹ See federal programs.

No jury in an ERISA slayer dispute. Because a claim to ERISA plan benefits is equitable, one federal court struck a jury demand in an interpleader where the estate relied on Tennessee’s slayer statute: reliance on the statute “does not change the nature of this proceeding as one to recover ERISA plan benefits.”¹⁵ See ERISA. In an ERISA accidental-death case, by contrast, the District of North Dakota held that ERISA does not preempt North Dakota’s slayer statute.

When the accused beneficiary never answers. A slayer question does not always have to be decided. In Symetra Life Ins. Co. v. Broderick (W.D. Tex. 2022), the magistrate judge’s report states that the insured’s husband, the primary beneficiary, killed her and was in prison. He never answered the interpleader. The court discharged the insurer and directed that no further proceedings be filed until the criminal matter against him was resolved; it then entered default judgment for the insured’s mother, the contingent beneficiary, applying the rule that “[w]hen only one of the claimants named in an interpleader action has answered, the court need not consider the merits of which party is entitled to the funds.”¹⁶ Texas’s insurance provision would have sent the money to the contingent beneficiary in any event.¹⁴

Military group life insurance (SGLI and VGLI)

Servicemembers’ Group Life Insurance and Veterans’ Group Life Insurance follow a federal order of payment. The money goes first to the beneficiary the insured designated in writing and, “if there be no such beneficiary, to the widow or widower,” then to children and other relatives.¹⁷ A Department of Veterans Affairs regulation supplies the slayer rule. The proceeds “shall not be payable” to “[a] person who is convicted of intentionally and wrongfully killing the decedent or determined in a civil proceeding to have intentionally and wrongfully killed the decedent,” or to someone convicted of, or found to have, assisted or aided such a person. The bar applies even while a conviction or civil determination is on appeal, and the money then passes to the next person in the regulation’s order of precedence.¹⁸ Federal employees’ group life insurance (FEGLI) has its own statutory order of precedence.¹⁹ See federal programs.

A default judgment that did not decide the slayer question. In Prudential v. Iturbide, a California federal case, a servicemember insured under SGLI died on February 19, 2018. His spouse was the primary beneficiary and his mother the secondary beneficiary. The insurer’s complaint recited that the spouse had been charged in connection with the death and asserted that she “may be disqualified” under Hawaii’s slayer statute, Haw. Rev. Stat. § 560:2-803, and the federal regulation, 38 C.F.R. § 9.5(e).²⁰ A charge is an accusation, not a finding, and no conviction or civil finding appears in the court’s orders. The insurer deposited the benefit and was discharged.²¹ The spouse was served but did not answer, and the court entered default judgment against her on the mother’s application. It noted that her incarceration “might hamper her participation in this action” but inferred that her default “was not the product of excusable neglect,” and it held that with her default “there are no other remaining claimants to the Proceeds.”²⁰ The court awarded the benefit to the mother because the only competing claimant had defaulted. It did not decide whether the regulation or the Hawaii statute applied, and it made no finding about the death. The Hawaii statute is mentioned here only because the court’s order recited it; Hawaii’s rule appears in the state table. See the case summary.

Deaths in vehicle crashes

Many slayer disputes involve a crash rather than a deliberate attack, and the answer turns on the mental state the rule requires. Some rules reach only intentional killings. Others also reach reckless conduct but not negligence.

A crash and a federal regulation. Prudential v. West involved VGLI coverage on an insured who died on May 24, 2019. The insurer’s pleadings described the death as following a vehicle crash and raised, in general terms, whether the VGLI slayer regulation might bar the surviving spouse, and the insurer filed an interpleader naming her and the insured’s children.²² The regulation’s text applies to a person convicted of, or found in a civil proceeding to have committed, an “intentionally and wrongfully” caused killing,¹⁸ so a death in a crash does not fit it easily. In July 2020 the court discharged the insurer and dismissed it from the case once the benefit was deposited.²³ The claimants later settled; under the court’s final judgment, entered on their joint motion, most of the benefits went to the surviving spouse and the rest to the insured’s three children.²⁴ (Read the final judgment.) No court decided whether the regulation applied, and no court made any finding about the death.

A conviction that did not settle the question. In Prudential v. Govel, a federal court in New York considered a beneficiary who had pleaded guilty to second-degree vehicular manslaughter after a motorcycle crash that killed the insured, his passenger. New York’s rule reaches intentional and reckless killings but not criminally negligent homicide. The court held that the conviction did not automatically bar him, because that offense can be committed with only criminal negligence. It then denied summary judgment to both sides, because a reasonable jury could find either way on whether his conduct that night was reckless. The court also noted that ERISA did not preempt New York’s slayer rule in that case.²⁵

State-by-state table

The table lists each state’s main provision on killing as a bar to inheriting or collecting. “Who is barred” quotes or paraphrases the operative words. The last column shows how each row was checked:

• Official means the editors read the statute on a legislature or government website. “Search excerpt” means the editors read the operative text as returned from that website by a search tool rather than on the page itself.
• Unofficial means the editors read the full text on a reputable unofficial site, such as Justia or a published copy of a state’s annotated code. A “dated copy” may not include recent amendments.
• Court quotation means the editors read the text as quoted in a published court opinion.
• Not fully verified means the editors could not read the operative text. Treat that row as a lead only.

How courts have ruled

Standard v. Guy and Transamerica v. Guy: one family, two states

A son killed both of his parents in Tennessee in November 2016. The insurers on the parents’ coverage filed interpleaders in 2018, one in Tennessee over the mother’s employer plans and one in Louisiana over an accidental death certificate covering both parents. Both cases were stayed until the criminal case ended at trial: about 25 months in Tennessee and about 20 in Louisiana.

• Tennessee (ERISA). After the son was convicted of first-degree premeditated murder, the district court refused to keep the case stayed through his appeal, because “nothing in Tennessee’s slayer statute indicates that a judgment of conviction must be final to be conclusive evidence.” It held him disqualified under Tenn. Code Ann. § 31-1-106(g), under which a conviction “is conclusive evidence that the individual is the decedent’s killer,” and alternatively under federal common law.⁴¹ The Sixth Circuit affirmed in a published opinion. It did not decide whether ERISA preempts Tennessee’s statute, holding that, “[a]ssuming that ERISA preempts Tennessee’s slayer statute, the federal common-law slayer rule controls,” and the son could not recover under either.⁴² Under the judgment, the mother’s siblings received $584,478.84 in equal shares and the father’s two daughters $117,597.85 in equal shares, with prorated interest.
• Louisiana. The court held that a conviction is a “final judgment” under La. R.S. 22:901(D) even while an appeal is pending, and that disqualifying a beneficiary on that basis does not violate due process. The father’s daughters took the son’s share of the father’s benefit, and the mother’s benefit went through her late mother’s succession to her siblings.⁴³ See the decision summary and Louisiana.

When the insurer has already paid the suspect

Usually an insurer that learns a beneficiary may be responsible for the death holds the money. In Wilty v. Prudential, a Tennessee federal case under ERISA, the insurer had already paid the death benefit to the insured’s widow when other claimants sued. The insurer counterclaimed for interpleader and sought a temporary restraining order. The court granted it, finding the insurer likely to succeed on its constructive trust claim because investigators had not ruled the widow out as a suspect and a finding that she willfully or intentionally caused or procured the death “would almost certainly prevent her from retaining or recovering” the money under the slayer statutes. It cited Tennessee’s, Mississippi’s and New Jersey’s. A consent order then froze what remained in her account, required her to return part of the benefit, and provided for both sums to be deposited in the court’s registry. The insurer’s request for a preliminary injunction was withdrawn without prejudice until it was decided whether a slayer rule applied.⁴⁴ The court later stayed the case pending a related criminal case, and news reports say the widow was charged in the death in March 2019.⁴⁵ The parties settled in November 2021. In the court’s consent order, the widow waived and released any claim to the death benefit, a guardian ad litem appointed for the insured’s minor daughter reported that the settlement was in her best interests, and the registry funds were distributed between the remaining claimants.⁴⁶ No court decided the slayer question. See When a claimant sues first.

If you are involved

• If you are a beneficiary under suspicion: do not discuss the facts of the death with the insurer, the other claimants, or their lawyers without advice from a criminal defense lawyer. Statements in a civil case can be used in a criminal one.
• If you are another family member: the insurer will usually hold the money until a court decides. Depending on the state, a civil court may be able to decide the question without a conviction, but a civil case may be delayed while a criminal case is pending. Where there is a conviction, many statutes make it conclusive; Illinois’ statute, for example, treats a conviction of first or second degree murder as conclusive.⁴⁷
• Either way: read named in an interpleader for the deadlines that apply once a case is filed.

Footnotes

1. Riggs v. Palmer, 115 N.Y. 506, 22 N.E. 188 (1889). ↩

2. Haw. Rev. Stat. § 560:2-803(b), (c), (e), (g), (h) (UPC § 2-803 as enacted in Hawaii). Hawaii State Legislature. Massachusetts, New Mexico, and other states that follow the current UPC section use substantially similar language; Minnesota’s version is older and differs in its details. ↩ ↩² ↩³

3. O.C.G.A. § 53-1-5(a), (d), and official commentary; § 33-25-13. Current (2025) text read on Justia (unofficial): § 53-1-5, § 33-25-13. Georgia’s official online code is hosted by a commercial publisher and could not be read for this check. ↩ ↩² ↩³ ↩⁴

4. Utah Code § 75-2-803(1)(d), (7). Utah Legislature. ↩ ↩²

5. Fla. Stat. § 732.802. Florida Legislature. ↩

6. Primerica Life Ins. Co. v. Donley, No. 3:18-cv-00995-AKK (N.D. Ala.): final judgment, ECF No. 40 (Oct. 30, 2019), at 1–3, court judgment (PDF); order granting discharge and fees, ECF No. 38 (Oct. 22, 2019), court order (PDF); order appointing guardian ad litem, ECF No. 21 (Feb. 4, 2019); order granting deposit, ECF No. 6 (July 16, 2018). ↩

7. Mo. Rev. Stat. § 461.054. Missouri Revisor of Statutes. ↩

8. First Unum Life Ins. Co. v. Marshall, No. 4:23-cv-00901-DGK (W.D. Mo.): order re proposed scheduling order, ECF No. 16 (Feb. 29, 2024), at 1–2; text order lifting stay, ECF No. 19 (Apr. 30, 2024); insurer’s notice of settlement and motion to stay, ECF No. 20 (May 6, 2024), at 1; joint stipulation of dismissal with prejudice, ECF No. 22 (May 20, 2024), at 1–3 (all three cited by docket number). The case settled; no court ruled on the slayer statute or on whether state or federal law governed the plan. ↩

9. Mass. Gen. Laws ch. 190B, § 2-803(b), (h). Massachusetts Legislature. The official comment is reproduced in Mass.gov’s unofficial version. ↩ ↩² ↩³

10. Minn. Stat. § 524.2-803(d). Minnesota Revisor of Statutes. ↩

11. Hartford Life & Accident Ins. Co. v. Jones-Atchison, No. 20-6135 (10th Cir. Sept. 20, 2021) (unpublished), govinfo (PDF), at 3 & n.2; Hartford Life & Accident Ins. Co. v. Jones-Atchison, No. 5:17-cv-00654 (W.D. Okla.), order, ECF No. 79 (Aug. 23, 2019), at 2, court order (PDF). ↩

12. Hartford Life & Accident Ins. Co. v. Jones-Atchison, No. 5:17-cv-00654 (W.D. Okla.), agreed order for disbursement, ECF No. 101 (May 20, 2020). ↩

13. C.R.S. § 15-11-803(7)(b). Colorado General Assembly, Colorado Revised Statutes 2024, Title 15 (uncertified printout). ↩

14. Tex. Ins. Code §§ 1103.151–.152. Texas Constitution and Statutes. ↩ ↩²

15. Sun Life Assurance Co. of Canada v. Estate of Jordi, No. 2:18-cv-00055 (M.D. Tenn.), memorandum order striking jury demand, ECF No. 59 (Aug. 5, 2020), at 3 n.2, 4, 6 (cited by docket number); final judgment, ECF No. 68 (Oct. 16, 2020), court judgment (PDF). The insurer was dismissed by ECF No. 39 (Oct. 1, 2018); the case was stayed by ECF No. 42 (Oct. 15, 2018) and the stay lifted by ECF No. 47 (May 13, 2020). ↩

16. Symetra Life Ins. Co. v. Broderick, No. 1:21-cv-00721-RP (W.D. Tex.), report and recommendation of the United States magistrate judge, ECF No. 20 (May 2, 2022), at 1–3, court order (PDF); order adopting report and recommendation, ECF No. 24 (July 27, 2022), court order (PDF); default judgment, ECF No. 25 (July 27, 2022), court judgment (PDF); amended order for disbursement, ECF No. 28 (Aug. 15, 2022); final judgment, ECF No. 29 (Oct. 11, 2022), court judgment (PDF). The discharge order is order granting interpleader relief and discharge, ECF No. 19 (May 2, 2022). ↩

17. 38 U.S.C. § 1970(a). Cornell LII. ↩

18. 38 C.F.R. § 9.5(e)(1)–(4). eCFR; Cornell LII. The bar itself is in paragraphs (e)(1) and (e)(2); paragraph (e)(4)(i) sets out who is paid instead. ↩ ↩²

19. 5 U.S.C. § 8705(a). Cornell LII. ↩

20. Prudential Ins. Co. of America v. Iturbide, No. 8:18-cv-01325-JLS-ADS (C.D. Cal. Apr. 24, 2019), ECF No. 33 (civil minutes granting default judgment), at 1–2, 8–9. Court order (PDF). The court’s account of the charge is a recital of the insurer’s complaint. ↩ ↩²

21. Order granting discharge and dismissal, Iturbide, ECF No. 29 (C.D. Cal. Feb. 27, 2019), court order (PDF); order for deposit, ECF No. 14 (Oct. 29, 2018). ↩

22. Prudential Ins. Co. of America v. West, No. 5:20-cv-00029-SL (N.D. Ohio filed Jan. 7, 2020), complaint, ECF No. 1, referred to here only generically. A complaint’s allegations are not findings, and the court made none about the death. ↩

23. Order for Relief in Interpleader, West, ECF No. 30 (N.D. Ohio July 14, 2020). ↩

24. Final Judgment and Order of Interpleader Disbursement, West, ECF No. 51 (N.D. Ohio Feb. 26, 2021) (entered on the claimants’ joint motion after the insurer deposited the funds on or about July 24, 2020, and was terminated as a party). ↩

25. Prudential Ins. Co. of America v. Govel, No. 1:16-cv-00297 (N.D.N.Y. June 6, 2017), ECF No. 78. govinfo (PDF). ↩

26. Ala. Code § 43-8-253(a), (c), (e), as amended by Act 2026-287. Alabama Legislature. ↩

27. AS 13.12.803. Alaska Legislature. ↩

28. Ark. Code §§ 18-4-201, -202 (Arkansas Slayer Law); § 28-11-204. Current text read on Justia (unofficial, 2025 code). Arkansas’ official online code is hosted by a commercial publisher and could not be read for this check, so the wording has not been verified against official text; § 28-11-204 was not rechecked. ↩

29. Cal. Prob. Code § 252. California Legislative Information. ↩

30. C.R.S. § 15-11-803(1)(b), (7). Colorado General Assembly, Colorado Revised Statutes 2024, Title 15 (uncertified printout). Subsection (7)(b) lets a court decide “by a preponderance of evidence standard” whether the elements of a felonious killing are established. ↩

31. Conn. Gen. Stat. § 45a-447(a)(1). Section text read on the Connecticut General Assembly’s site, chapter 802b. ↩

32. Ind. Code § 29-1-2-12.1. Indiana General Assembly. ↩

33. La. R.S. 22:901(D). Louisiana State Legislature. ↩

34. Md. Code, Est. & Trusts § 11-112(a), (d), (j). Maryland General Assembly. Current text; the version in effect on a given date may differ. ↩

35. Miss. Code Ann. § 91-1-25. Current (2025) text read on Justia (unofficial); the same words are quoted in In re Estate of Miller, 840 So. 2d 703 (Miss. 2003), and in Garden State Life Ins. Co. v. Estate of Raine, No. 2:17-cv-103-KS-JCG (S.D. Miss. Sept. 25, 2018) (Justia, unofficial), which also states the preponderance-of-the-evidence burden. Mississippi’s official online code is hosted by a commercial publisher and could not be read for this check. ↩

36. N.J.S.A. 3B:7-1.1. New Jersey Legislature. ↩

37. NMSA § 45-2-803(B), (G). Justia (unofficial). The official New Mexico Compilation Commission site (NMOneSource) refused automated access, so the wording has not been verified against official text. ↩

38. Riggs v. Palmer, 115 N.Y. 506 (1889), New York State Law Reporting Bureau. New York’s rule is court-made. A narrow statute, EPTL 4-1.6, bars a joint tenant convicted of first- or second-degree murder of the other from the joint bank account except for the killer’s own contributions; its text was read on Justia (unofficial) because the official New York Senate site blocked automated access. The absence of a general statute was not verified against official text. See New York. ↩

39. Tenn. Code § 31-1-106(a)(2), (b), (g). Current (2025) text read on Justia (unofficial). Tennessee’s official online code is hosted by a commercial publisher and could not be read for this check. ↩

40. RCW 11.84.010, .020, .100, .110, .140. Washington State Legislature. ↩

41. Standard Ins. Co. v. Guy, No. 2:18-cv-00074 (E.D. Tenn.), order, ECF No. 70 (Dec. 1, 2020), court order (PDF), at 2; memorandum opinion and order, ECF No. 120 (May 20, 2021), court order (PDF), at 4–6; judgment, ECF No. 121 (May 20, 2021), court judgment (PDF). ↩

42. Standard Ins. Co. v. Guy, 115 F.4th 518 (6th Cir. 2024), slip op. at 5, 12, court copy (PDF); Sixth Circuit (PDF). ↩

43. Transamerica Premier Life Ins. Co. v. Guy, No. 2:18-cv-07993 (E.D. La.), order and reasons, ECF No. 63 (June 28, 2021), at 16–17, 22–26, court order (PDF); final judgment, ECF No. 66 (Sept. 20, 2021), court judgment (PDF). ↩

44. Wilty v. Prudential Ins. Co. of America, No. 2:18-cv-02602-JTF (W.D. Tenn.): order granting TRO, ECF No. 29 (Sept. 25, 2018), court order (PDF); consent order, ECF No. 41 (Nov. 7, 2018). ↩

45. Order, Wilty, ECF No. 51 (W.D. Tenn. Sept. 22, 2021); WREG, “One year later, Olive Branch woman charged with murder after man found dead in street” (Mar. 2019), WREG. A charge is an accusation, not a finding. ↩

46. Consent order, Wilty v. Prudential Ins. Co. of America, No. 2:18-cv-02602-JTF (W.D. Tenn. Nov. 19, 2021), ECF No. 55, ¶¶ 1–3, 8. Court order (PDF). ↩

47. 755 ILCS 5/2-6 (read on the Illinois General Assembly website). ↩