In the 1942 case of Ettelson et al. v. Metropolitan Life Insurance Co., the U.S Supreme Court ruled in favor of Metropolitan Life Insurance Company, upholding its right to refuse payment on a life insurance policy due to misrepresentation by the insured party during application. The plaintiff, Ettelson, was seeking recovery under two policies issued by Metropolitan on her late husband's life who had misrepresented his health condition while applying for insurance coverage. He failed to disclose that he suffered from heart disease and diabetes which led to his death within two years after obtaining the policies. The court held that if an applicant makes false representations as part of their application process which materially affects risk assessment or acceptance decision made by insurer then such contract can be voided even if death is caused by another illness not related with undisclosed conditions.

In the dissenting opinion for Ettelson et al. v. Metropolitan Life Insurance Co., Justice Frank Murphy argued that the majority's decision was a misinterpretation of Illinois law, which he believed did not require an insurance policy to be in effect at the time of death for beneficiaries to receive benefits. He contended that it only required premiums to have been paid up until the point of disability onset and maintained that this interpretation would better serve public interest by providing financial protection for families during times of hardship caused by illness or injury. Furthermore, he criticized the majority's reliance on technicalities rather than considering broader principles and implications related to social justice and welfare.