Peoples Security Life Insurance v. Arrington

In this appeal we consider whether the common law doctrine that no person should be permitted to profit by his own wrong has been superseded by Title 55, Chapter 22, entitled “Acts Barring Property Rights,” Code §§ 55-401 to -415. Acts 1981, ch. 469.

On March 13, 1988, Charles Arrington was stabbed and shot to death while he and his wife, Delores, were in their automobile. No one has been prosecuted for the murder of Mr. Arrington. However, Mrs. Arrington remains available for prosecution.

Mrs. Arrington was the beneficiary of an insurance policy on the life of her deceased husband, issued by…