In Grant v. Phoenix Life Insurance Company, the Supreme Court of the United States was asked to decide whether a life insurance policy was valid when the insured had not paid the premiums. The insured, Grant, had taken out a life insurance policy with Phoenix Life Insurance Company. He had paid the first premium, but had not paid the subsequent premiums. When Grant died, his widow attempted to collect on the policy, but Phoenix Life Insurance Company refused to pay, citing the fact that the premiums had not been paid. The Supreme Court held that the policy was valid and enforceable, despite the fact that the premiums had not been paid. The Court reasoned that the policy was a contract between the parties, and that the insured had a reasonable expectation that the policy would be enforced. The Court also noted that the policy was not a wager, and that the insured had not intended to gamble on his life. The Court concluded that the policy was valid and enforceable, and that the widow was entitled to the proceeds of the policy. This decision established that life insurance policies are contracts, and that they are enforceable even if the premiums have not been paid.

Justice Field delivered the dissenting opinion in Grant v. Phoenix Life Insurance Company, arguing that the majority's decision was wrongfully decided and should be reversed. He argued that under Arizona law, a life insurance policy is an absolute contract between two parties which cannot be changed without mutual consent of both parties. The majority had held that because the insured had not paid his premiums on time, he forfeited all rights to any benefits from the policy; however Justice Field disagreed with this conclusion as it violated Arizona law by allowing one party to unilaterally change a contract without agreement from both sides. Furthermore, he noted that even if there were some ambiguity in interpreting Arizona law regarding forfeiture of benefits due to nonpayment of premiums, such ambiguities should have been resolved in favor of protecting the insured rather than punishing him for failing to pay on time. In sum, Justice Field believed strongly that since no provision existed within either state or federal laws authorizing insurers to forfeit their obligations upon late payment by an insured party - and since such action would violate existing contracts - then it must follow logically that no forfeiture could occur here either and thus Grant was entitled to receive full benefits under his insurance policy despite having failed timely payments