In Roberts v. Phoenix Life Insurance Company, the Supreme Court of the United States was asked to decide whether a life insurance policy was valid when the insured had died before the policy was delivered. The Court held that the policy was valid and enforceable. The case arose when the plaintiff, Roberts, purchased a life insurance policy from the defendant, Phoenix Life Insurance Company. The policy was issued and the premium was paid, but the policy was never delivered to Roberts. Roberts died before the policy was delivered, and his estate sought to recover the proceeds of the policy. The defendant argued that the policy was not valid because it had not been delivered. The Court held that the policy was valid and enforceable. The Court reasoned that the policy was binding when it was issued and the premium was paid, and that the delivery of the policy was not necessary to make it valid. The Court noted that the policy was a contract between the parties, and that the parties had agreed to the terms of the policy. The Court also noted that the policy was a contract of adhesion, meaning that the insured had no choice but to accept the terms of the policy. The Court concluded that the policy was valid and enforceable, and that the plaintiff's estate was entitled to recover the proceeds of the policy.

Justice Field delivered the dissenting opinion in Roberts v. Phoenix Life Insurance Company, arguing that the majority's decision was inconsistent with prior Supreme Court precedent and would lead to a "confusion of rights" between insurance companies and their policyholders. He argued that under existing law, an insurer is not liable for any loss or damage caused by its failure to perform its obligations unless it has been guilty of fraud or bad faith. In this case, he believed there was no evidence of either fraud or bad faith on behalf of the defendant company; therefore, they should not be held liable for damages resulting from their breach of contract. Furthermore, Justice Field noted that if insurers were allowed to escape liability without proof of fraud or bad faith then policyholders would have little incentive to pay premiums on time as they could simply wait until after a claim had been made before paying up - something which could potentially bankrupt many life insurance companies across America.