In Baylis v. Travellers' Insurance Company, the Supreme Court of the United States was asked to decide whether a contract of insurance was valid and enforceable. The plaintiff, Baylis, had purchased a policy of insurance from the defendant, Travellers' Insurance Company, which provided coverage for any loss or damage to his property caused by fire. Baylis subsequently suffered a loss due to a fire, and sought to recover the amount of the loss from the insurance company. The insurance company refused to pay, arguing that the policy was invalid because it had not been signed by the company's president, as required by the company's bylaws. The Supreme Court held that the policy was valid and enforceable, despite the fact that it had not been signed by the company's president. The Court reasoned that the bylaws of the company did not require the president's signature in order for the policy to be valid, and that the policy was binding on the company regardless of whether it had been signed by the president. The Court also held that the company was estopped from denying the validity of the policy, as it had accepted the premium payments and had not objected to the policy until after the loss had occurred. As a result, the Court held that the insurance company was liable for the loss suffered by Baylis.

Justice Field delivered the dissenting opinion in Baylis v. Travellers' Insurance Company, arguing that the majority's decision was contrary to established precedent and would lead to a dangerous expansion of liability for insurance companies. He argued that while it is true that an insurer must pay out on claims made under its policies, this does not mean they are liable for any damages caused by their insureds. In this case, he noted there was no evidence presented at trial showing any negligence or fault on behalf of the insurer which could have contributed to the plaintiff's injury; rather, all responsibility lay with those who had actually committed the act causing harm. Furthermore, Justice Field argued that allowing such expansive liability would be detrimental both to insurers and society as a whole since it would encourage frivolous lawsuits against them without providing sufficient protection from unjustified claims. Ultimately then, he concluded that if insurers were held responsible for every action taken by their insureds regardless of whether they had acted negligently or not then "the business [of insurance] will become so hazardous as scarcely ever again to be undertaken."