320 U.S. 430, 438-439
Magnolia Petroleum Company employed respondent Hunt, a resident of Louisiana, as a laborer in connection with the drilling of oil wells.1 Hunt went from Louisiana to Texas in the course of his employment, and while working there for Magnolia on an oil well, he was injured by a falling drill stem.2 He sought and procured in Texas an award of compensation for his injury under its Workmen's Compensation Law, and Magnolia's insurer made payments of compensation as required by the statute and the award.3
The award became final in accordance with the terms of the Texas statute.4 Respondent then brought the present proceeding in the Louisiana District Court to recover compensation for his injury under the Louisiana Workmen's Compensation Law.5 Magnolia filed exceptions to respondent's petition on the ground that the recovery sought was barred as res judicata by the Texas award which, by virtue of the constitutional command, was entitled in the Louisiana courts to full faith and credit.6
The District Court overruled the exceptions and gave judgment for the amount of the compensation fixed by the Louisiana statute, after deducting the amount of the Texas payments.7 The Louisiana Court of Appeal affirmed, and the Supreme Court of Louisiana refused writs of certiorari and review for the reason that it found no error of law in the judgment complained of.8 The Supreme Court of the United States granted certiorari because of the importance of the constitutional question presented and to resolve an apparent conflict of the decision below with its prior decisions.9
Whether under the full faith and credit clause an award of compensation for personal injury under the Texas Workmen's Compensation Law bars a further recovery of compensation for the same injury under the Louisiana Workmen's Compensation Law?10
Yes. The Texas award became final without appeal and constitutes a conclusive adjudication under Texas law of the employee's right to compensation for the injury in lieu of any other recovery.13
The award resolved the rights of the parties arising from the single injury sustained in Texas employment.14 Therefore the full faith and credit clause mandates that Louisiana courts treat the award as res judicata.15
The Texas compensation award bars further recovery of compensation for the same injury under the Louisiana Workmen's Compensation Law.16
Related opinions on this issue
Justice Jackson concurs in the result because the principles announced in Williams v. North Carolina require reversal of the Louisiana decision.17 He notes that Louisiana possesses a legitimate interest in the subject matter but observes that North Carolina held an equivalent interest in marital status that could not override the prior adjudication.18 Jackson concludes that he remains bound by Williams until it is overruled and therefore concurs in applying full faith and credit to bar the second proceeding.19
Joined by Justice Murphy
Justice Douglas dissents on the ground that the Texas award adjudicated only rights under Texas law and did not purport to regulate the Louisiana employment contract or extinguish claims under Louisiana statutes.20 He argues that full faith and credit does not prevent Louisiana from granting supplemental compensation when the Texas proceeding left the Louisiana cause of action untouched.21 Douglas distinguishes Schendel because the two statutes here are not mutually exclusive.22
He would accommodate the competing state interests rather than allow one to obliterate the other.23
Joined by Justices Douglas, Murphy, And Rutledge
Justice Black dissents because Texas did not intend its award to bar Louisiana claims, the employer was not a party to the Texas proceeding, and Louisiana retains a paramount interest in protecting its resident employees under local compensation policy.24 He contends that the decision improperly converts the full faith and credit clause into a barrier against state experimentation with workmen's compensation remedies.25 Black concludes that the clause does not require one state to give greater effect to another's judgment than the rendering state itself intended.26