Evidence of Intent to Commit Life Insurance Fraud Appropriate to Prove Murder

Jail House Informant Provides Motive for Murder

Murder to collect on a life insurance policy is one of the most egregious forms of insurance fraud and destroys the claims of those who think insurance fraud is a non-violent crime. Murder is not the only violent form of insurance fraud, but it is probably the most serious. Like all insurance criminals, even a convicted murderer will refuse to accept his conviction, and will do everything possible to change the results of a jury trial.

In Mattei v. the State, S19A1332, Supreme Court of Georgia (November 4, 2019) following a jury trial, Paul Joseph Mattei was found guilty of malice murder, aggravated assault, and various other offenses in connection with the shooting death of Angela Williams. On appeal, Mattei contends that the evidence presented at trial was insufficient to support his convictions and that the trial court erred by admitting at trial character evidence in violation of Georgia statutes.

FACTS

Two months prior to the murder, Williams and Mattei had entered into a “marriage of convenience.” The two did not move in together and kept their marriage largely a secret. Williams told a family member that the purpose of the marriage was for her to assist Mattei with a drug trafficking scheme involving a trip to the Bahamas. The same day that they married, Mattei added Williams as his spouse to his insurance policy. Under the terms of Mattei’s family-rider policy, Mattei would collect $150,000 upon his spouse’s accidental death.

On the night of her murder, Williams was scheduled to meet with Mattei to discuss their travel plans. Video surveillance recordings from surrounding businesses showed Williams’s vehicle following Mattei’s truck in the direction of the parking lot where she was shot, just ten minutes before the shooting. The recordings also showed his truck driving away from the scene shortly before rescue vehicles arrived.

Police discovered that searches for how to obtain a death certificate had been made on Mattei’s computer hours after Williams’s shooting. The police also discovered that Mattei had made three inquiries between June 18, 2011 and July 4, 2011, checking on his life insurance policy. In a search of Mattei’s vehicle after his arrest, police found paperwork that could be used to file a life insurance claim along with information on how to obtain a death certificate. On August 12, 2011, after obtaining the death certificate from Williams’s daughter, Mattei notified the insurance company of Williams’s death.

At trial, Crystal Bridges, Mattei’s former roommate, testified that shortly after she moved in with Mattei in December of 2009, he approached her about an insurance fraud scheme involving him running her over with his truck so they could file an insurance claim. A jailhouse informant, Marlon Avila, testified that in July of 2013, he and Mattei were housed in the same unit. During that time, Mattei told Avila that he had shot his wife three times with a .380 handgun. An analysis of the shell casings recovered from Williams’s car showed she had been shot by a .380 handgun.

ANALYSIS

Viewed, as an appellate court must, in the light most favorable to the verdicts, the evidence showed that on the evening of June 30, 2011 Mattei shot Angela Williams twice in the chest and once in the arm, while Williams sat in her car in an isolated parking lot in Fairburn, Georgia. Mattei then left the scene in his yellow truck, and Williams managed to drive herself a little over one half of a mile to a gas station, where police found her barely conscious. Despite being rushed to the hospital, she was pronounced dead upon arrival. The Fulton County medical examiner concluded that Williams’s death was caused by a gunshot wound to the chest.

Mattei attacked Avila’s testimony regarding his confession as “uncorroborated and unreliable.” Based on the foregoing, the court concluded that the evidence was sufficient to enable a rational trier of fact to conclude beyond a reasonable doubt that Mattei was guilty of the crimes for which he was convicted.

Next, Mattei contended that the trial court erred by admitting into evidence Bridges’s testimony.

The insurance scheme was not admitted to show Mattei’s alleged propensity to commit the charged offense of murder or some other crime with which he was charged, but was relevant to his potential reason for killing his wife.

Relevant evidence is evidence having any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence. The State needed the extrinsic evidence to rebut Mattei’s contention that his act of insuring Williams and his possession of paperwork for filing an insurance claim were consistent with the normal activities of a newly married husband, rather than the actions of a person who was motivated to kill his wife in an effort to collect insurance proceeds.

Furthermore, the conversation with Bridges occurred just 18 months before Williams’s death, meaning it was not “so remote as to be lacking in evidentiary value.”

Any danger of unfair prejudice to Mattei was mitigated by a limiting instruction that the trial court gave to the jury. The Supreme Court concluded that the trial court did not abuse its discretion in admitting Bridges’s testimony at Mattei’s trial to show his potential motive to commit the murder at issue in this case.

ZALMA OPINION

Insurance policies should never pay the beneficiary who killed the insured as Mattei killed Williams, his wife. The fact of the insurance, the search for necessary documents to prove a life insurance claim, and the confession to a jail mate, were more than sufficient to establish a motive to kill Williams. Although motive is not necessary to prove the crime of murder, showing a motive makes it easier for a trier of fact to convict. May Mattei spend the rest of his life in prison.


© 2019 – Barry Zalma

This article, and all of the blog posts on this site, digest and summarize cases published by courts of the various states and the United States.  The court decisions have been modified from the actual language of the court decisions, were condensed for ease of reading, and convey the opinions of the author regarding each case.

Barry Zalma, Esq., CFE, now limits his practice to service as an insurance consultant  specializing in insurance coverage, insurance claims handling, insurance bad faith and insurance fraud almost equally for insurers and policyholders. He also serves as an arbitrator or mediator for insurance related disputes. He practiced law in California for more than 44 years as an insurance coverage and claims handling lawyer and more than 50 years in the insurance business. He is available at http://www.zalma.com and zalma@zalma.com.

Mr. Zalma is the first recipient of the first annual Claims Magazine/ACE Legend Award.

Over the last 51 years Barry Zalma has dedicated his life to insurance, insurance claims and the need to defeat insurance fraud. He has created the following library of books and other materials to make it possible for insurers and their claims staff to become insurance claims professionals.

 

 

About Barry Zalma

An insurance coverage and claims handling author, consultant and expert witness with more than 48 years of practical and court room experience.
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