In the case of Manhattan Life Insurance Company of New York v. Cohen, Executor (1913), the U.S Supreme Court ruled in favor of Manhattan Life Insurance Company. The dispute arose when Mr. Cohen, as executor for his deceased brother's estate, claimed that a life insurance policy issued by Manhattan Life was still valid despite non-payment of premiums due to his brother's insanity at the time they were due. However, according to the terms and conditions set forth by Manhattan Life Insurance Company in their policies, failure to pay premiums would result in termination regardless of reasons behind it. The court held that an insured person’s incapacity or insanity does not excuse them from paying premiums on their life insurance policy unless there is specific provision made within the contract itself stating otherwise. As such provisions did not exist within this particular contract between Mr.Cohen’s late brother and Manhattan Life Insurance company; hence it was decided that no exception could be made for him regarding payment deadlines.

In the dissenting opinion for Manhattan Life Insurance Company of New York v. Cohen, Executor, 1913, Justice Holmes argued that the court should not have ruled in favor of Cohen because it was inconsistent with previous rulings on similar cases. He believed that the majority's decision to allow a life insurance policy to be collected by an executor who had no insurable interest in the deceased was contrary to public policy and could potentially encourage murder for financial gain. Furthermore, he disagreed with their interpretation of New York law regarding this matter and felt they were overstepping their jurisdiction by ruling on state law issues instead of federal ones. Ultimately, he concluded that if such policies are allowed under state laws then those laws themselves may need revision but until then they should be upheld as written.