Aetna Life Insurance v. Haworth Case Brief Summary | Law Case Explained
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Aetna Life Insurance v. Haworth, 300 U.S. 227 (1937)
The Constitution’s Case-or-Controversy Clause limits the kinds of matters federal courts are allowed to hear. The Supreme Court has read into the clause a ban on advisory opinions, meaning that a federal court can’t consider pure questions of law presented without an underlying dispute between actual parties. In Aetna versus Haworth, the Court explored the difference between an impermissible advisory opinion and a permissible declaratory judgment.
Between 1911 and 1929, Aetna Life Insurance Company issued Edwin Haworth 5 life-insurance policies worth a total of $40,000. The policies specified that if Haworth became totally and permanently disabled, he’d no longer have to pay premiums and he’d be entitled to certain benefits. During the early 1930s, Haworth informed Aetna that he was totally and permanently disabled and ceased paying his premiums, but he didn’t make a claim for benefits.
Aetna filed a federal declaratory judgment action against Haworth. Specifically, Aetna requested a declaration that four of the policies were null and void for nonpayment and the 5th policy only required Aetna to pay $45 upon Haworth’s death. The district court dismissed the complaint, reasoning that the matter wasn’t a justiciable case or controversy under the Federal Declaratory Judgment Act. The Eighth Circuit affirmed, and the United States Supreme Court granted cert.
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