In the case of Doyle v. London Guarantee and Accident Company, Limited (1906), the U.S Supreme Court ruled in favor of Doyle. The dispute arose when Mr. Doyle was injured while working on a construction project insured by London Guarantee and Accident Company, Limited. He filed for compensation under an insurance policy that covered accidents resulting from "elevator risks." However, his claim was denied as he had been injured not directly by the elevator but due to a fall caused by stepping into an unguarded elevator shaft opening. The court held that although Mr. Doyle's injury did not result directly from using or operating an elevator, it fell within the scope of "elevator risks" as defined in the insurance policy because it resulted from conditions inherent to elevators' operation - namely open shafts which are necessary for their function but can pose hazards if left unguarded. Therefore, despite arguments made by London Guarantee and Accident Company asserting otherwise based on literal interpretations of terms used in its policies' language; such narrow interpretation would defeat reasonable expectations about what kinds of injuries should be considered 'risks associated with elevators.' Hence they were liable to compensate him under said policy.

In the dissenting opinion for Doyle v. London Guarantee and Accident Company, Limited, Justice Holmes disagreed with the majority's interpretation of the insurance contract in question. He argued that it was not reasonable to assume that an insurer would agree to cover risks associated with a third party's negligence without explicitly stating so in the policy. Furthermore, he contended that if such coverage were intended, it should have been reflected in higher premiums charged by the insurer. The justice also pointed out inconsistencies between this case and previous rulings on similar issues where courts had found no liability on part of insurers under comparable circumstances. Thus, according to him, there was no basis for holding London Guarantee liable for damages resulting from a third party’s negligent act which led to Mr.Doyle’s injury.