State seizes prisoner's life insurance proceeds and he is not allowed to waive receipt

Wayne Snyder was imprisoned in 1999.  When his mother died, Snyder was to receive life insurance proceeds in the amount of $2500.00.  The State Treasurer seized the proceeds, however, and obtained a court order granting the state 90% of the insurance money  under the Correctional Facility Reimbursement Act.  Snyder appealed.

Snyder argued that the State's claim was moot because he had formally disclaimed any interest in the insurance proceeds.  The Court of Appeals held that while insurance proceeds may be a "disclaimable" interest under the law, the latter right is not absolute.  It held that allowing the DPIL "disclaimer" statute to subvert the intent of the SCFRA would lead to an "absurd result:" the State would need a prisoner's consent to secure reimbursement.  Therefore, the lower court judgment was affirmed and the State was allowed to seize the benefits which Snyder would have received as a beneficiary of his mother's life insurance.