In the case of New York Life Insurance Company v. Cravens in 1899, the US Supreme Court ruled on a dispute involving an insurance policy claim. The beneficiary, Mrs. Cravens, argued that her husband's life insurance policy was still valid at his time of death despite him not paying premiums for several months prior to his passing due to severe illness which incapacitated him from managing his affairs including payment of premiums. The New York Life Insurance Company contended that Mr. Craven’s failure to pay these premiums resulted in the termination of his coverage before he died and thus they were not liable for any payout. The court sided with Mrs.Cravens stating that under Missouri law (where this case originated), if an insured person becomes so ill as to be unable to manage their own affairs then it is incumbent upon the insurer - once aware or should have been aware -to make reasonable efforts towards collecting premium payments before declaring a policy lapsed due non-payment. This ruling established precedent regarding insurers' obligations when dealing with severely ill clients who may be incapable of maintaining their policies.

In the dissenting opinion for New York Life Insurance Company v. Cravens, Justice Harlan argued that the majority's decision was inconsistent with established legal principles and precedent. He contended that an insurance policy is a contract between two parties, and as such, it should be interpreted according to its terms without any external influence or bias. In this case, he believed that Mr. Cravens had clearly violated the terms of his life insurance policy by committing suicide; therefore, New York Life Insurance Company should not be obligated to pay out on his policy. Furthermore, Justice Harlan disagreed with the majority's interpretation of "accidental death," arguing that it did not include self-inflicted harm or suicide because these actions are intentional rather than accidental in nature.