In the Northwestern National Life Insurance Company v. Riggs case of 1906, the U.S Supreme Court ruled in favor of Mrs. Riggs who was contesting a life insurance policy claim from Northwestern National Life Insurance Company following her husband's death. The company had denied payment on grounds that Mr. Riggs had misrepresented his health condition during application for the policy by not disclosing he suffered from Bright's disease (a historical classification of kidney diseases). However, it emerged that at the time of application and issuance of policy, Mr.Riggs was unaware he had this disease; hence there was no intentional misrepresentation or fraud involved as claimed by the insurer. The court held that an applicant is only required to disclose conditions they are aware about at time of applying for coverage and cannot be penalized for failing to reveal unknown ailments even if these later cause their demise.

In the dissenting opinion for Northwestern National Life Insurance Company v. Riggs, Justice Harlan argued that the majority's decision was a departure from established principles of insurance law. He contended that when an insured person makes false representations in their application, it does not automatically void their policy unless those misrepresentations were material to the risk being assumed by the insurer. In this case, he believed there was no evidence showing that Mrs. Riggs' incorrect answers materially affected her insurability or influenced Northwestern's decision to issue her a policy. Therefore, he disagreed with the majority's ruling in favor of Northwestern and would have upheld Mrs.Riggs' right to recover under her life insurance policy despite any inaccuracies in her application.