Beets v. State

In Beets v. State, 767 S.W.2d 711, 734 (Tex. Crim. App. 1987), the indictment alleged the murder was committed "for remuneration or the promise of remuneration." While Beets did not explicitly turn on either of these grounds, the court nonetheless emphasized in italics the term "for remuneration" in its analysis of whether a person who kills in the expectation of collecting life insurance proceeds has committed a capital offense. Beets, 767 S.W.2d at 734-35. Further, in its conclusion, the court completely omitted discussion of "for the promise of remuneration." It stated, "we hold, therefore, that a person commits a murder for remuneration . . . where the actor kills a victim in order to receive a benefit or financial settlement paid upon the death of the victim, such as proceeds of insurance and retirement benefits as in the present case." Id. at 737.