But it became the constant practice of Coroner’s juries to find that persons who had been proved to have destroyed themselves were suffering from “temporary insanity”: they thus avoided a verdict of felo-de-se; hence arose the necessity of an understanding whether or not “Suicide whilst insane” did or did not vitiate a policy. In equity, of course, such a death should not do so, because the death occurs without the voluntary determination of a healthy mind, and no one can contract himself out of the possibility of some day losing his reason. The difficulty might never have arisen, but for this unfortunate straining of the word insanity to cover all cases of suicide. On the Continent, in many States, this injudicious mode of regarding suicides does not exist; when madmen kill themselves, their madness is registered; and when persons whom no one has ever noticed to be unable to manage their affairs, and whose mental state has not been disturbed, until they have preferred death to life, on account of some loss or annoyance, their voluntary deaths are registered as such. In those states unseemly squabbles between assurance companies and executors are quite rare. To dispute and refuse payment, however, was found by the companies not altogether a profitable business, because such cases gave rise to much discussion and more misrepresentation, and the litigating company was apt to be avoided by persons about to choose a company to insure with. Several cases which appeared to be attempts at fraud have been the subject of investigation in courts of law. See reports of the suits of Borrodaile _v._ Hunter, 1841; Schwabe _v._ Clift, 1845; Isett _v._ The American Insurance Company; and The St. Louis Insurance Company _v._ Graves. In the first case, a clergyman jumped off Vauxhall Bridge into the Thames and was drowned; in his case the policy stated that it should be avoided if the assured should “die by his own hands.” At the trial, Erskine, J., told the jury the policy must be void if the deceased jumped into the water, intending to kill himself, and knowing that this action would kill him; he also left it to them to say whether the deceased could, at the time of his death, distinguish right from wrong. The jury became confused, for they found that the deceased threw himself off with _intent_ to destroy himself, and also that he was not capable of deciding right from wrong. The verdict was entered for the defendants, that is, that deceased was felo-de-se. On Appeal, the case was argued before four judges in 1843; they, however, differed in opinion; three judges held that it was felo-de-se, and one that the assured was temporarily insane, and that his death was due to an insane uncontrollable impulse.