In Phoenix Life Insurance Company v. Walrath, the Supreme Court of the United States was asked to decide whether a life insurance policy was valid and enforceable. The plaintiff, Phoenix Life Insurance Company, had issued a policy to the defendant, Walrath, in which the company agreed to pay a certain sum of money to Walrath's estate upon his death. Walrath had paid the premiums for the policy, but had failed to pay the last premium due before his death. The company argued that the policy was void because of the unpaid premium, while Walrath's estate argued that the policy was still valid and enforceable. The Supreme Court held that the policy was valid and enforceable. The Court reasoned that the policy was a contract between the parties, and that the company had received the premiums due up to the time of Walrath's death. The Court further held that the policy was not void because of the unpaid premium, as the company had not declared the policy void or taken any other action to indicate that it was no longer in effect. The Court concluded that the policy was valid and enforceable, and that the company was obligated to pay the sum due to Walrath's estate.

In Phoenix Life Insurance Company v. Walrath, the Supreme Court was asked to decide whether a life insurance policy issued by Phoenix Life Insurance Company (Phoenix) to Charles Walrath (Walrath) had lapsed due to nonpayment of premiums. The majority opinion held that the policy had indeed lapsed and that no further payments were owed on it. In his dissent, Justice Field argued that under New York law at the time, which governed this case, there was an implied agreement between Phoenix and Walrath for an extension of time in which he could make payment on his premium without forfeiting coverage under the policy. He reasoned that since such extensions were common practice among insurers in New York at the time and since both parties knew about them when they entered into their contract, they should be considered part of its terms even if not explicitly stated in writing. Furthermore, he noted that while some evidence suggested Walrath may have been delinquent with respect to paying his premiums prior to this incident, nothing indicated any intention or desire on either party's part for him to forfeit coverage under his policy as a result thereof; thus implying an agreement between them for additional time beyond what was initially provided before forfeiture would occur.