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Angle v. North-Western Mutual Life Insurance Company was a United States Supreme Court case that addressed the issue of whether a life insurance policy was validly issued. The plaintiff, Angle, had purchased a life insurance policy from the defendant, North-Western Mutual Life Insurance Company. Angle later died, and his widow attempted to collect the proceeds of the policy. North-Western refused to pay, claiming that the policy was invalidly issued. The Supreme Court held that the policy was validly issued. The Court found that the policy was issued in accordance with the terms of the insurance contract, and that the company had not acted in bad faith. The Court also found that the company had not breached any of its obligations under the contract. The Court concluded that the policy was validly issued, and that the plaintiff's widow was entitled to the proceeds of the policy.
In Angle v. North-Western Mutual Life Insurance Company, the Supreme Court was asked to decide whether a life insurance policy could be assigned without the consent of the insurer. The majority opinion held that such an assignment was not valid and did not bind the insurer because it had never consented to it. Justice Field dissented from this decision, arguing that since there is no provision in either state or federal law prohibiting assignments of life insurance policies without consent, they should be allowed as long as all parties involved are aware of them and agree to their terms. He further argued that if insurers were able to prevent assignments by refusing their consent, then those who purchased policies would have little incentive for doing so since they would lack any assurance that their beneficiaries would receive payment upon death due to potential refusal from insurers on assignment requests.