In the case of Equitable Life Assurance Society v. Brown in 1902, the U.S Supreme Court ruled on a dispute involving an insurance policy claim. The plaintiff, Mrs. Brown, was seeking to recover money from her late husband's life insurance policy with Equitable Life Assurance Society after he committed suicide while allegedly insane. The insurer denied payment based on a clause in the contract that excluded coverage for suicide "whether sane or insane." However, Mrs. Brown argued this exclusion was contrary to public policy and should not be enforced if her husband had been mentally ill at his time of death. The court sided with Equitable Life Assurance Society stating that it is within an insurer's rights to limit their liability under certain conditions as long as those limitations do not contravene statutory law or public policy; they found no such violation here since there were no laws prohibiting insurers from excluding suicides from coverage regardless of mental state at death.

In the dissenting opinion for Equitable Life Assurance Society v. Brown, Justice Harlan argued that the majority's decision was a misinterpretation of Alabama state law and an overreach of federal power. He contended that Alabama courts had already determined their own laws regarding insurance policies, which stated that all premiums paid on a policy should be returned if it is canceled before its maturity date. The majority's ruling contradicted this established precedent by allowing the insurance company to keep these premiums despite canceling the policy early. Furthermore, Justice Harlan criticized his colleagues for intervening in what he saw as a matter of state jurisdiction; he believed it was not within their purview to reinterpret or override existing state laws unless they were clearly unconstitutional.