New England Mutual Life Insurance Co. v. Woodworth

New England Mutual Life Insurance Co. v. Woodworth, 111 U.S. 138 (1884), was a U.S. Supreme Court case.

New England Mutual Life Insurance Co. v. Woodworth
Argued March 18, 1884
Decided March 31, 1884
Full case nameNew England Mutual Life Insurance Company v. Woodworth, Adm'r etc.
Citations111 U.S. 138 (more)
4 S. Ct. 364; 28 L. Ed. 379
Holding
Reaffirmed the general rule that simple contract debts, such as a policy of insurance not under seal, are, for the purpose of founding administration, assets where the debtor resides, without regard to the place where the policy is found.
Court membership
Chief Justice
Morrison Waite
Associate Justices
Samuel F. Miller · Stephen J. Field
Joseph P. Bradley · John M. Harlan
William B. Woods · Stanley Matthews
Horace Gray · Samuel Blatchford
Case opinion
MajorityBlatchford, joined by unanimous

The caseEdit

On September 21, 1869, Ann E. Woodworth took out a life insurance policy on herself with the New England Mutual Life Insurance Company in Michigan. Her husband Stephen E. Woodworth was the beneficiary. She then died in New York, and her husband moved to Illinois. The company did not pay the policy, and he sued in Illinois. The Illinois court passed judgment against the insurance company. The insurance company appealed saying that the suit should not have been filed in Illinois.

The Supreme Court reaffirmed the general rule that simple contract debts, such as a policy of insurance not under seal, are, for the purpose of founding administration, assets where the debtor resides, without regard to the place where the policy is found.[1]

Used as precedentEdit

This case was used as a precedent in 8 SCOTUS cases and 21 cases by other courts. The SCOTUS precedent citations include:

  • Southern Pacific Co. v. Denton (1892)
  • Shaw v. Quincy Mining Co. (1892),
  • Fitzgerald & Mallory Constr. Co. v. Fitzgerald (1890)
  • Barrow SS Co. v. Kane (1898),
  • In Re the Louisville Underwriters (1890)
  • In Re Keasbey & Mattison Co. (1895)
  • Equitable Life Assurance Soc. v. Brown (1902)[2]
  • Connecticut Mut. Life Ins. Co. V. Moore (1948)[3]

Side effect of the caseEdit

The plaintiff, Stephen E. Woodworth, was both the Step-Father and Uncle of noted entomologist Charles W. Woodworth. C.W. Woodworth's mother became a widow and married her late husband's brother who was a widower. The judgment arrived when C.W. Woodworth was 19 and likely helped pay for his education at the University of Illinois.[4]

See alsoEdit

ReferencesEdit

  1. ^ NEW ENGLAND MUTUAL LIFE INS. CO. v. WOODWORTH, Adm'r, etc. Decision Cornell Legal Information Institute
  2. ^ 28 Opinions cite New England Mut. Life Ins. Co. v. Woodworth, 111 U.S. 138 Decision Court Listener
  3. ^ "CONNECTICUT MUT. LIFE INS. CO. V. MOORE, 333 U.S. 541 (1948) FindLaw
  4. ^ Holden, Brian (2015). Charles W. Woodworth: The Remarkable Life of U.C.'s First Entomologist. Brian Holden Publishing. p. 71. ISBN 978-0-9864105-3-6.

External linksEdit