In the 1892 case of Miles v. Connecticut Mutual Life Insurance Company, the U.S. Supreme Court was tasked with determining whether an insurance company could refuse to pay out a life insurance policy on the grounds that the insured had committed suicide while insane. The court ruled in favor of Miles, stating that unless explicitly stated otherwise in the contract, an insurer cannot deny payment based on such circumstances. The decision hinged largely upon interpretation of language within contracts and policies; if no specific clause regarding mental illness or suicide is included, it should not be assumed or inferred by either party involved in said agreement.

In the dissenting opinion for Miles v. Connecticut Mutual Life Insurance Company, Justice Brewer argued that the insurance company should not be held liable for damages because they were acting in good faith based on information provided by a third party. He contended that it was unreasonable to expect an insurer to verify every statement made by an applicant or their physician, especially when there is no reason to suspect falsehoods. Furthermore, he pointed out that if insurers were required to investigate all statements thoroughly before issuing policies, it would significantly increase costs and potentially make insurance unaffordable for many people. Therefore, he believed that as long as insurers acted in good faith without any knowledge of false representations from applicants or physicians, they should not be penalized.