In the case of Hartford Life Insurance Company v. Douds et al., Executors of Douds, 1922, the U.S Supreme Court was tasked with determining whether a life insurance policy could be considered an asset in probate court after the death of its holder. The case arose when Mr. Douds died and his executors attempted to include his life insurance policy as part of his estate for distribution among beneficiaries. However, Hartford Life Insurance Company argued that since they had already paid out on the policy to Mrs. Douds (the designated beneficiary), it should not be included in Mr.Doud's estate assets. The Supreme Court ruled in favor of Hartford Life Insurance Company stating that once a life insurance company has fulfilled its obligation by paying out on a policy upon death, it is no longer an asset and cannot be counted towards any outstanding debts or obligations left behind by the deceased individual.

The dissenting opinion in the case of Hartford Life Insurance Company v. Douds et al., argued that the majority's decision to uphold a New York law requiring foreign corporations to pay taxes on their entire net income, regardless of where it was earned, was unconstitutional. The dissenters believed this violated both the Due Process and Commerce Clauses of the Constitution. They contended that states should only be able to tax income generated within their borders and not from interstate or international commerce activities. Furthermore, they pointed out inconsistencies with previous court rulings which had struck down similar state laws as unconstitutional under these same clauses. In essence, they felt that upholding such a law would set a dangerous precedent allowing states to impose undue burdens on interstate commerce and infringe upon federal authority over such matters.