In the case of Iowa Life Insurance Company v. Lewis in 1902, the U.S Supreme Court was tasked with determining whether a life insurance policy could be voided due to misrepresentation or concealment by the insured party. The court ruled that if an individual seeking life insurance knowingly and willfully provides false information or conceals material facts during their application process, then this constitutes fraud. This fraudulent behavior gives insurers grounds to rescind policies even after death benefits have been claimed. In this particular case, Mr. Lewis had concealed his alcoholism when applying for his policy with Iowa Life Insurance Company which led to its cancellation upon discovery after his death.

In the dissenting opinion for Iowa Life Insurance Company v. Lewis, it was argued that the majority's decision to uphold a state law requiring out-of-state insurance companies to maintain certain levels of reserves as a condition of doing business in the state violated principles of interstate commerce. The dissent contended that such laws unfairly discriminated against foreign corporations and impeded their ability to compete on equal terms with domestic companies. It also suggested that if every state enacted similar legislation, it could lead to an untenable situation where insurance firms would be required to hold multiple reserve funds across various states, thereby creating unnecessary financial burdens and inefficiencies. Furthermore, they believed this ruling contradicted previous court decisions which had struck down similar laws on grounds they interfered with interstate trade.