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 case

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.

Side effect of the case

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.

See also

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