In the case of Aetna Life Insurance Co. et al. v. Moses, 1932, the United States Supreme Court ruled in favor of the defendant, Mr. Moses, who had been sued by Aetna Life Insurance for refusing to pay premiums on a life insurance policy after he became totally disabled and unable to work due to an accident. The court held that under New York law (where Mr. Moses resided), total disability was defined as being unable "to engage in any substantial gainful work," which meant that he was not required to continue paying premiums on his life insurance policy during this time period despite what his contract with AETNA stipulated otherwise about premium payments during periods of disability.

In the dissenting opinion for AETNA LIFE INSURANCE CO. et al. v. MOSES, Justice Stone argued that the majority's decision to allow a state court to enforce an insurance policy provision was inconsistent with previous rulings of the Supreme Court and violated principles of federalism. He contended that by allowing a state court to interpret and apply its own law in such cases, it would undermine uniformity in insurance regulation across states and potentially lead to conflicting interpretations of similar provisions in different jurisdictions. Furthermore, he believed this could disrupt interstate commerce as insurers might face differing legal obligations depending on where they operate or sell policies. Thus, he disagreed with the majority's ruling because it failed to respect established precedents regarding jurisdictional boundaries between federal and state courts.