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National Life Insurance Company v. Scheffer

1881 • 131 U.S. cciii • Waite Court
National Life Insurance Company v. Scheffer was a United States Supreme Court case that dealt with the issue of whether a life insurance policy could be voided due to a misrepresentation of age. The plaintiff, National Life Insurance Company, had issued a policy to the defendant, Scheffer, in which he had misrepresented his age. The company sought to void the policy on the grounds that the misrepresentation was material to the risk assumed by the company. The Supreme Court held that the...Open Case
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Chief Waite Court
Term: 1881
Docket: 273
131 U.S. cciii
26 L. Ed. 1110
1882 U.S. LEXIS 1284
Argued: Apr 11, 1882

National Life Insurance Company v. Scheffer

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Opinion Summary
AI Abstract

National Life Insurance Company v. Scheffer was a United States Supreme Court case that dealt with the issue of whether a life insurance policy could be voided due to a misrepresentation of age. The plaintiff, National Life Insurance Company, had issued a policy to the defendant, Scheffer, in which he had misrepresented his age. The company sought to void the policy on the grounds that the misrepresentation was material to the risk assumed by the company. The Supreme Court held that the misrepresentation was material and that the policy could be voided. The Court reasoned that the misrepresentation was material because the company had relied on the accuracy of the age stated in the policy in order to determine the risk it was assuming. The Court also noted that the company had not been aware of the misrepresentation until after the policy had been issued. The Court's decision established that a life insurance policy can be voided if the insured has made a material misrepresentation of age. This decision has been cited in numerous subsequent cases involving life insurance policies and misrepresentations of age.

Dissent Summary
AI Abstract

In National Life Insurance Company v. Scheffer, the Supreme Court was tasked with determining whether a contract between an insurance company and its policyholder could be enforced when it had been procured by fraud. The majority opinion held that the contract should not be enforced due to public policy considerations, but Justice Field dissented from this view. He argued that while fraudulent acts are generally disfavored in law, they do not necessarily invalidate contracts; rather, courts must consider all of the circumstances surrounding each case before making a decision on enforceability. Furthermore, he noted that if parties were allowed to escape their contractual obligations simply because one party committed fraud during negotiations or execution of the agreement then no contracts would ever be secure and commerce would suffer greatly as a result. Therefore, Justice Field concluded that any attempt to set aside such agreements should only occur after careful consideration of all relevant facts and evidence presented in court proceedings so as to ensure justice is served for both parties involved in the dispute.

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