In the 1940 case Stoner v. New York Life Insurance Co., the U.S Supreme Court ruled in favor of the plaintiff, Mr. Stoner, who had sued his insurance company for denying him disability benefits after he suffered a stroke that left him unable to work. The court held that an insured person does not need to be completely helpless or bedridden to qualify as "totally disabled" under their policy terms and conditions. Instead, it was enough if they were unable to perform all substantial and material acts necessary for pursuing their occupation in a customary manner. This ruling set a precedent by defining what constitutes total disability within insurance law context.

In the dissenting opinion for Stoner v. New York Life Insurance Co., it was argued that the majority's decision failed to properly consider and apply relevant state law, which should have been controlling in this case. The dissent contended that under California law, a policyholder has an absolute right to change beneficiaries at any time before their death unless there is clear evidence of fraud or undue influence. In this case, no such evidence existed; therefore, Mr. Stoner had every right to change his beneficiary from his wife (the plaintiff) to another party without her consent or knowledge. Furthermore, they disagreed with the majority's interpretation of "irrevocable" as used in insurance policies arguing that it only means one cannot revoke or alter a designation once made except by agreement with the insurer and not necessarily requiring spousal approval.