Ritter v. Mutual Life Ins. Co. of New York - 169 U.S. 139 (1898)
U.S. Supreme Court
Ritter v. Mutual Life Ins. Co. of New York, 169 U.S. 139 (1898)
Ritter v. Mutual Life Insurance Company of New York
Argued December 3, 6, 1897
Decided January 17, 1898
169 U.S. 139
This was an action on six policies of insurance, all alike (except as to the amount of insurance) and in the following form:
"In consideration of the application for this policy, which is hereby made a part of this contract, the Mutual Life Insurance Company of New York promises to pay at its home office in the City of New York, unto William M. Runk, of Philadelphia, in the County of Philadelphia, Pennsylvania, his executors, administrators or assigns, twenty thousand dollars, upon acceptance of satisfactory proofs at its home office of the death of the said William M. Runk during the continuance of this policy, upon the following condition, and subject to the provisions, requirements and benefits stated on the back of this policy, which are hereby referred to and made part hereof. The annual premium of seven hundred and eighty-two dollars shall be paid in advance on the delivery of this policy, and thereafter to the company at its home office in the City of New York, on the tenth day of November in every year during the continuance of this contract. In witness whereof,"
etc. The principal defense was that the assured, when in sound mind, deliberately and intentionally took his own life, whereby the event insured against -- his death -- was precipitated. One of the issues was the sanity or insanity of the assured when he committed self-destruction. Held:
(1) If the assured understood what he was doing, and the consequences of his act or acts, to himself as well as to others -- in other words, if he understood, as a man of sound mind would, the consequences to follow from his contemplated suicide, to himself, his character, his family and others, and was able to comprehend the wrongfulness of what he was about to do, as a sane man would, then he is to be regarded as sane.
(2) In the case of fire insurance, it is well settled that, although a policy, in the usual form, indemnifying against loss by fire, may cover a loss attributable merely to the negligence or carelessness of the insured, unaffected by fraud or design, it will not cover a destruction of the property by the willful act of the assured himself in setting fire to it, not for the purpose of avoiding a peril of a worse kind but with the intention of simply effecting its destruction.
(3) Much more should it be held that it is not contemplated by a policy taken out by the person whose life is insured and stipulating for
the payment of a named sum to himself, his executors, administrators, or assigns that the company should be liable if his death was intentionally caused by himself when in sound mind. When the policy is silent as to suicide, it is to be taken that the subject of the insurance -- that is, the life of the assured -- shall not be intentionally and directly, with whatever motive, destroyed by him when in sound mind. To hold otherwise is to say that the occurrence of the event upon the happening of which the company undertook to pay was intended to be left to his option. That view is against the very essence of the contract.
(4) A contract the tendency of which is to endanger the public interests or injuriously affect the public good or which is subversive of sound morality ought never to receive the sanction of a court of justice or be made the foundation of its judgment.
(b) If, therefore, a policy -- taken out by the person whose life is insured and in which the sum named is made payable to himself, his executors, administrators or assigns -- expressly provided for the payment of the sum stipulated when or if the assured, in sound mind, took his own life, the contract, even if not prohibited by statute, would be held to be against public policy in that it tempted or encouraged the assured to commit suicide in order to make provision for those dependent upon him or to whom he was indebted. The case is not different in principle if the policy be silent as to suicide and the event insured, the death of the assured, is brought about by his willful, deliberate act when in sound mind.
The case is stated in the opinion.