AETNA LIFE INSURANCE CO. v. HAWORTH ET AL., 300 U.S. 227

Under the Federal Declaratory Judgment Act of 1934 (Act), 28 U.S.C.S. § 400, plaintiff sought a decree that certain insurance policies be declared null and void by reason of lapse for nonpayment of premiums. The trial court dismissed plaintiff's suit upon the ground that there was no justiciable controversy. That determination was affirmed by the lower court. The United States Supreme Court held that plaintiff's complaint contained a justiciable controversy. Specifically, it held that the existence of the total and permanent disability of the insured and the continuance of plaintiff's obligations despite the nonpayment of premiums were issues that presented an actual controversy within the meaning of the Act. Noting that the Act incorporated a purely constitutional standard, the Court reversed the decree of the lower court and remanded for further proceedings pursuant to that statute.