In the 1897 case of Ritter v. Mutual Life Insurance Company of New York, the U.S Supreme Court ruled in favor of the insurance company. The dispute arose when Mr. Ritter's life insurance policy was canceled due to non-payment of premiums while he was seriously ill and unable to manage his affairs. After his death, Mrs. Ritter sued for payment under the policy but lost at trial and on appeal because she had not provided evidence that her husband’s illness prevented him from paying or understanding his obligations under the contract with Mutual Life Insurance Company of New York.

In the dissenting opinion for Ritter v. Mutual Life Insurance Company of New York, it was argued that the majority's decision to uphold a policy forfeiture due to non-payment of premium was unjust. The dissenting justices believed that the insurance company had not provided sufficient notice or opportunity for payment before declaring the policy void. They contended that such harsh consequences should only be enforced when there is clear evidence of intentional default on part of the insured party, which they did not find in this case. Furthermore, they criticized what they saw as an overly strict interpretation and application of contract law by their colleagues in favor of corporations over individuals' rights and interests.