Johnson v. New York Life Insurance

Background

A person holding a life insurance policy sued after benefits were disputed, arguing that New York law required thirty days’ notice before any policy forfeiture. The Iowa Supreme Court reviewed the issue, concluded the New York statute did not apply because the policy was a non-forfeitable term policy that had expired by limitation before the insured’s death, and ruled for the insurer. The losing party then sought review here, claiming the Iowa courts failed to give full faith and credit to New York’s notice law.

Reasoning

The Court addressed whether a federal constitutional right had been denied. It held the claimant did not properly present that federal claim: under the governing statute a constitutional title, right, privilege, or immunity must be specially claimed, and the issue was not raised in the motion for a new trial or in the assignments of error in the Iowa courts but first appeared only in the petition to this Court. The Court also explained the Iowa court had considered and cited New York decisions and had construed the New York statute as inapplicable to the particular policy, so no federal question was presented.

Real world impact

Because the federal claim was not timely or specially raised and the state court resolved the case by construing the statute, this Court dismissed the writ of error and left the state-court judgment intact. The ruling makes clear that parties must raise federal constitutional claims clearly in state proceedings to preserve review by this Court. Two Justices, White and McKenna, dissented.