Mutual Life Insurance Co. of New York v. Hillmon 145 U.S. 285, 12 S. Ct. 909, 36 L. Ed. 706 (1892)
Hillmon was a cattle rancher from Kansas. He was
traveling with a guy named Brown looking for a good site to build a new
Brown came out of the prairie in Colorado and claimed that
he had accidentally shot and killed Hillmon.
A body was found in a creek where Brown said it would be.
Hillmon's wife claimed that it was his body and asked the
insurance company for her insurance money.
Mutual Life countered that the body was that of another
man, Walters, who had left Iowa and disappeared in Kansas.
Mutual Life was suspicious because Hillmon recently took
out three massive insurance policies on himself that he couldn't afford.
Mutual argued that Hillmon and Brown had conspired to
murder Walters and use his body to collect the insurance money.
The body was dressed in Hillmon's clothes and carrying
Hillmon's wife sued the insurance companies to get her
At trial, Mutual Life attempted to introduce letters from
Walters just before he disappeared saying that he was going with Hillmon
Mrs. Hillmon objected on the grounds that the letters
Mutual Life argued that under the common law, statements
made in the present state of mind are admissible as an exception
The Trial Judge rejected the letters.
The Trial Court found for Hillmon. Mutual Life appealed.
The US Supreme Court reversed and ordered a new trial.
The US Supreme Court looked to the common law and found
that evidence of intention is an exception to hearsay.
The Court found that the letters could not used to prove
that Walters did go to Colorado with Hillmon, but they could be
used to show that Walters intended to go to Colorado with
"Wherever the bodily or mental feelings of an
individual are material to be proved, the usual expressions of such
feelings are original and competent evidence."
This case established "the Hillmon Doctrine"
which says that, the state of mind of the declarant can be used
inferentially to prove other matters that are in issue.
"When the performance of a particular act by an
individual is an issue in a care, his intention to perform that act may
be shown. From that intention, the factfinder may draw the inference that
the person carried out his intention and performed the act."
Basically, if a person says that they are going to do an
act, then that statement is relevant evidence that can be used to help
prove that they actually did the act.
It isn't conclusive proof, but it can help.
Interestingly, there is evidence that the insurance
companies forged Walter's letter. If so, a whole doctrine of evidence was
based on a lie.