Aetna Life Ins. Co. v. Haworth

Aetna Life Ins. Co. v. Haworth, 300 U.S. 227 (1937) announced the meaning of "controversy" in the constitutional sense as follows: A "controversy" in this sense must be one that is appropriate for judicial determination. A justiciable controversy is thus distinguished from a difference or dispute of a hypothetical or abstract character; from one that is academic or moot. The controversy must be definite and concrete, touching the legal relations of parties having adverse legal interests. It must be a real and substantial controversy admitting of specific relief through a decree of a conclusive character, as distinguished from an opinion advising what the law would be upon a hypothetical state of facts . . . . 300 U.S. at 240-41, 57 S. Ct. at 464 . In Aetna, the controversy concerned a specific insured, four specific life insurance policies, and a complaint that the policies be declared null and void by reason of lapse for nonpayment of premiums. Id. at 237, 239, 57 S. Ct. at 462-63. Such facts constituted a controversy in the constitutional sense. Id. at 244, 57 S. Ct. at 465.