Even though a contract does not directly require any unlawful or improper act for its performance, if the tendency of the contract is to encourage or hold out a reward for a result that can be brought about only by an unlawful act, the contract is opposed to public policy. Illustrations of this have already been given with reference to agreements to secure legislation, but the principle is a general one.14

It has generally been held that an insurance policy which makes no express condition excepting death by suicide, covers the case of such death even though the insured was sane.15 The Supreme Court of the United States, however, has not only held that in the absence of express words covering death by suicide while sane the insurance contract must be interpreted as excluding death by such a cause, but has added that even though the contract should in terms provide for payment in spite of the fact that the insured while sane committed suicide, such a provision would be opposed to public policy.16

102 Man. 167, 173. As in the case of torts, a man has a right to expect lawful conduct from others. In order to charge him with the consequences of the act of an intervening wrongdoer, you must know that he actually contemplated the act. Hayes v. Hyde Park, 153 Mass. 514, 515, 516, 27 N. E. 522, 12 L. R. A. 249."

14 Sage v. Hampe, 235 U. S. 99, 59 L. Ed. 147, 35 S. Ct. 94. The court held invalid a contract which tended either to induce an Indian landowner to deprive himself of rights which the law sought to protect or to induce improper influence of Government officials. The fact that statutes permitted a conveyance with the approval of the Secretary of the Interior, was held not to validate the contract, since its tendency was to induce the contractor to bring to bear improper influence or attempts to influence on the Secretary of the Interior, or to mislead him as to the welfare of the Indian. See also Kelly v. Harper, 7 Ind. Ter.

541,104 S. W. 829; Larson v. First Nat. Bank, 62 Neb. 303, 308, 87 N. W. 18.

15 Grand Legion of Illinois v. Beaty, 224 HI. 346, 79 N. E. 565, 8 L. R. A. (N. S.) 1124; Seiler v. Economic L. Assn., 105 Iowa, 87, 74 N. W. 941, 43 L. R. A. 537; Supreme Conclave I. O. of H. v. Miles, 92 Md. 613, 48 Atl. 845, 84 Am. St. Rep. 528; Morton v. Supreme Council, 100 Mo. App. 76, 73 S. W. 259; Lange v. Royal Highlanders, 75 Neb. 188, 106 N. W. 224, 110 N. W. 1110, 10 L. R. A. (N. 8.) 666, 121 Am. St. Rep. 786; Campbell v. Supreme Conclave, 66 N. J. L. 274, 49 Atl. 550, 54 L. R. A. 576; Darrow v. Family Fund Soc., 116 N. Y. 537, 22 N. E. 1093, 6 L. R. A. 495, 15 Am. St. Rep. 430.

16 Ritter v. Mutual Life Ins. Co., 169 U. S. 139, 42 L. Ed. 693, 18 S. Ct. 300. See also Shipman v. Protected Home Circle, 174 N. Y. 398, 67 N. E. 83, 63 L. R. A. 347; Plunkett v. Supreme Conclave, 105 Va. 643, 55 S. E. 9.