The case of Order of United Commercial Travelers of America v. Wolfe (1946) revolved around the issue of whether a fraternal benefit society, in this instance the Order of United Commercial Travelers (UCT), could be held liable for refusing to pay out a death benefit claim on one its members. The UCT had denied payment based on their assertion that the deceased member, Mr. Wolfe, had misrepresented his health condition during application process and thus violated terms within his contract with them. However, Ohio state law at that time stipulated that if an insurance policy was not contested within two years after it was issued then it couldn't be later contested by insurers even if there were misrepresentations made during application process. The Supreme Court ruled against UCT stating they were subject to these same laws as traditional insurance companies despite being a fraternal organization. Therefore since they hadn't challenged Mr.Wolfe's policy within two year period post issuance; they were obligated to honor death benefits payout as per contractual agreement.

In the dissenting opinion for the case Order of United Commercial Travelers of America v. Wolfe, Justice Frank Murphy argued that the majority's decision was a departure from established principles of insurance law and an intrusion into state regulatory power. He contended that Ohio had a legitimate interest in protecting its citizens from ambiguous or misleading insurance policies and should be allowed to regulate such contracts as it saw fit. The justice believed that there was no constitutional right for insurers to issue confusing or deceptive policies, nor any obligation on states to recognize them if they did so. Furthermore, he disagreed with the majority's interpretation of "accidental means" in this context; he felt it could reasonably be understood by policyholders as referring not just to unintended actions but also unexpected results - thus covering Mr Wolfe’s death due his own action which led unintentionally fatal consequences.