This case was a dispute between the State of South Carolina and the Connecticut Mutual Life Insurance Company. The state had passed a law that required all insurance companies doing business in the state to pay a certain amount of taxes. The insurance company argued that the law was unconstitutional because it violated the Due Process Clause of the Fourteenth Amendment. The Supreme Court ruled in favor of the insurance company, finding that the law was unconstitutional because it violated the Due Process Clause. The Court held that the law was an unreasonable exercise of the state's power to tax and that it was an arbitrary and oppressive interference with the company's right to do business in the state. The Court also held that the law was not a valid exercise of the state's police power and that it was an unconstitutional interference with the company's right to contract. The Court concluded that the law was an unconstitutional violation of the Due Process Clause and that the insurance company was entitled to an injunction against its enforcement.

In Sea v. Connecticut Mutual Life Insurance Company, the Supreme Court was asked to decide whether a life insurance policy issued by the defendant company could be enforced against an assignee of the insured after it had been assigned without notice to the insurer. The majority opinion held that such assignment did not affect the rights of either party and that therefore, enforcement of said policy was proper. Justice Field dissented from this decision on two grounds: firstly, he argued that under common law principles, any transfer or assignment made without notice should be void; secondly, he contended that even if there were no common law principle in place prohibiting such assignments without notice then at least public policy considerations should prevent them from being enforceable as they would encourage fraud and deception upon insurers who are unable to protect themselves against these kinds of transfers due to their lack of knowledge about them. In conclusion Justice Field concluded his dissent with a statement saying “I cannot concur in holding…that one may acquire title by stealth” which effectively summed up his disagreement with both parts of the majority opinion's ruling.