Wash. Rev. Code » Title 11 · Chapter 11.84
Revised Code of Washington

Wash. Rev. Code § 11.84.100 (2026)

Insurance proceeds

✓ current as of May 2026
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(1) Insurance proceeds payable to the slayer or abuser as the beneficiary or assignee of any policy or certificate of insurance on the life of the decedent, or as the survivor of a joint life policy, shall be paid instead to the estate of the decedent, unless the policy or certificate designate some person other than the slayer or abuser or his or her estate as secondary beneficiary to him or her and in which case such proceeds shall be paid to such secondary beneficiary in accordance with the applicable terms of the policy.
(2) If the decedent is beneficiary or assignee of any policy or certificate of insurance on the life of the slayer or abuser, the proceeds shall be paid to the estate of the decedent upon the death of the slayer or abuser, unless the policy names some person other than the slayer or abuser or his or her estate as secondary beneficiary, or unless the slayer or abuser by naming a new beneficiary or assigning the policy performs an act which would have deprived the decedent of his or her interest in the policy if he or she had been living.
[ 2009 c 525 s 10; 1965 c 145 s 11.84.100. Prior: 1955 c 141 s 10.]
Notes of Decisions
Cited in 5 cases, 1975–2019 · leading case: Gail Michelman v. Lincoln Nat'l Life Insuranc, 685 F.3d 887 (9th Cir. 2012).
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Gail Michelman v. Lincoln Nat'l Life Insuranc, 685 F.3d 887 (9th Cir. 2012). “See Wash. Rev.Code § 11.84.100(1). If the slayer statute had precluded Gail from recovering the insurance proceeds, these funds would have been payable to Jessica, the contingent beneficiary.”
Messinger v. New York Life Ins., 581 P.2d 1381 (Wash. Ct. App. 1978). · cites it 3× “As an affirmative defense to payment to Kelley, the company pleaded Washington's slayer statute, RCW 11.84.100. 1 The policy proceeds were deposited with the court, together with $2,100.”
Certification From Fed. Court in New York Life Ins. v. Jones, 541 P.2d 989 (Wash. 1975). “RCW 11.84.100 1 reads as follows: (1) Insurance proceeds payable to the slayer as the beneficiary or assignee of any policy or certificate of insurance on the life of the decedent, or as the survivor of a joint life policy, shall be paid instead to the estate of the decedent,…”
California-W. States Life Ins. v. Sanford, 515 F. Supp. 524 (E.D. La. 1981). “1978); Wash.Rev.Code Ann. §§ 11.84.100, 11.84.130(1967).”
Securian Life Ins. Co. v. Reddeck (W.D. Wash. 2019). “Her parents (the “Derheim Family”) have asserted a claim to the life insurance 6 proceeds, asserting that the named beneficiary, Reddeck, should be treated as having 7 predeceased the Insured, based on the “slayer statute,” RCW 11.84.100. Id. Mr. Reddeck’s 8 father, Edward…”
— Wash. Rev. Code § 11.84.100(1) — 2 cases
Gail Michelman v. Lincoln Nat'l Life Insuranc, 685 F.3d 887 (9th Cir. 2012). “See Wash. Rev.Code § 11.84.100(1). If the slayer statute had precluded Gail from recovering the insurance proceeds, these funds would have been payable to Jessica, the contingent beneficiary.”
Messinger v. New York Life Ins., 581 P.2d 1381 (Wash. Ct. App. 1978). “As an affirmative defense to payment to Kelley, the company pleaded Washington's slayer statute, RCW 11.84.100. 1 The policy proceeds were deposited with the court, together with $2,100.”
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