Acacia Mutual Life Insurance v. Newcomb

The Chancellor :

Ellen Vandalier Newcomb, widow of William Thomas Newcomb, concedes that Lillian Elizabeth Cass must be regarded as the beneficiary of the proceeds of the policy of insurance on her husband’s life. O’Donnell v. Metropolitan Life Ins. Co., 11 Del. Ch. 4, 95 A. 289; Id., 11 Del. Ch. 404, 102 A. 163. She claims, however, that she is entitled to a lien on that fund because of the premiums paid on the policy by her from her own earnings during her husband’s lifetime.

Perhaps in most cases, an equitable lien on a particular • fund can be created only by a contract which, in express…