Northwestern National Life Insurance Co. v. Riggs

Northwestern National Life Insurance Co. v. Riggs, , was an important United States Supreme Court

Supreme Court of the United States

The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...

case dealing with corporations conducting business and the power of individual states to regulate how corporations may conduct business.

Facts

The conflict within the case involved the payment of a life insurance

Life insurance

Life insurance is a contract between an insurance policy holder and an insurer, where the insurer promises to pay a designated beneficiary a sum of money upon the death of the insured person. Depending on the contract, other events such as terminal illness or critical illness may also trigger...

claim made by Riggs for the estate of Eber B. Roloson against Northwestern National Life Insurance Company which Northwestern refused to pay saying that the deceased had made false statements concerning his medical history. The state of Missouri

Missouri

Missouri is a US state located in the Midwestern United States, bordered by Iowa, Illinois, Kentucky, Tennessee, Arkansas, Oklahoma, Kansas and Nebraska. With a 2010 population of 5,988,927, Missouri is the 18th most populous state in the nation and the fifth most populous in the Midwest. It...

had in place a series of legislative acts in the period of 1874 and 1889 that basically created a condition on any life insurance contract in which though medical history information may be inaccurate, if the inaccurate information had no bearing on the manner of the deceased's death then any claim must still be paid. If the inaccurate information did bear on the manner of the deceased's death or if there was a dispute concerning whether the information provided bore on the manner of the deceased's death then the matter was for a jury to decide whether the claim should be paid.

Trial

In a jury trial on a claim by Riggs for the estate of Roloson, Northwestern National requested that the jury be instructed that the Missouri statute "was not applicable to this case, and could not be applied to it consistently with the 14th Amendment of the Constitution of the United States". The jury was not so instructed. The trial resulted in a judgment against the defendant, Northwestern National Life Insurance Company.

Northwestern National appealed the judgment with the position the corporation's due process

Due process

Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...

rights under the Fourteenth Amendment had been violated.

Previous Supreme Court decisions had said that liberty "guaranteed by the 14th Amendment against deprivation otherwise than by due process of law embraces the right to pursue a lawful calling and enter into all contracts proper, necessary, and essential to the carrying out of the purposes of such calling." This interpretation of the Fourteenth Amendment

Fourteenth Amendment to the United States Constitution

The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...

had been applied to corporations as well as to individual people. The Court ruled that the Fourteenth Amendment was not a bar to many state

U.S. state

A U.S. state is any one of the 50 federated states of the United States of America that share sovereignty with the federal government. Because of this shared sovereignty, an American is a citizen both of the federal entity and of his or her state of domicile. Four states use the official title of...

laws that effectively limit a corporation's right to contract business so long as such limits were not unreasonable constraints on trade and due process for resolving conflicts and disputes existed.

Northwestern National's arguments were based on the fact that it was, as a corporation, an artificial "person" and hence subject to the protections afforded "persons" under that amendment, an argument which had been and was later used successfully to declare child labor

Child labor

Child labour refers to the employment of children at regular and sustained labour. This practice is considered exploitative by many international organizations and is illegal in many countries...

and minimum wage

Minimum wage

A minimum wage is the lowest hourly, daily or monthly remuneration that employers may legally pay to workers. Equivalently, it is the lowest wage at which workers may sell their labour. Although minimum wage laws are in effect in a great many jurisdictions, there are differences of opinion about...

laws unconstitutional

Constitutionality

Constitutionality is the condition of acting in accordance with an applicable constitution. Acts that are not in accordance with the rules laid down in the constitution are deemed to be ultra vires.-See also:*ultra vires*Company law*Constitutional law...

Judgment

The Court ruled to uphold the application of the Missouri statute, saying: