In the case of Wolfe v. Hartford Life and Annuity Insurance Company, 1892, the U.S Supreme Court was tasked with determining whether an insurance policy could be considered property that is subject to seizure by creditors. The plaintiff in this case, Mr. Wolfe had taken out a life insurance policy from the defendant company and named his wife as beneficiary. However, when he became insolvent due to financial difficulties, his creditors sought to seize the policy's cash value as part of their debt recovery efforts. The court ruled in favor of Mr. Wolfe stating that under Connecticut law (where both parties resided), a life insurance policy made payable upon death to a person other than oneself cannot be reached by one’s creditors during their lifetime because it does not constitute property owned by them but rather constitutes a contract for future payment contingent on death.

The dissenting opinion in the Wolfe v. Hartford Life and Annuity Insurance Company case argued that the majority's decision was incorrect because it failed to consider the specific language of the insurance policy at issue. The dissent pointed out that, according to this policy, benefits were only payable upon receipt of "due proof" of death - a requirement which had not been met by Mrs. Wolfe when she initially filed her claim due to lack of evidence about Mr. Wolfe's presumed death from drowning. Therefore, they contended that Hartford was within its rights under contract law to deny payment until such proof was provided as stipulated in their agreement with Mr.Wolfe.