U.S. Supreme Court
Thomas v. Washington Gas Light Co., 448 U.S. 261 (1980)
Thomas v. Washington Gas Light Co.
Argued March 19, 1980
Decided June 27, 1980
448 U.S. 261
Petitioner, a resident of the District of Columbia, received an award of disability benefits from the Virginia Industrial Commission under the Virginia Workmen's Compensation Act for injuries received in Virginia while employed by respondent employer (hereafter respondent), which was principally located in the District of Columbia, where petitioner was hired. Subsequently, petitioner received a supplemental award under the District of Columbia Workmen's Compensation Act over respondent's contention that since, as a matter of Virginia law, the Virginia award excluded any other recovery "at common law or otherwise" on account of the injury in Virginia, the District of Columbia's obligation to give that award full faith and credit precluded a second, supplemental award in the District. The administrative order upholding the supplemental award was reversed by the Court of Appeals, which held that the award was precluded by the Full Faith and Credit Clause.
598 F.2d 617, reversed and remanded.
MR. JUSTICE STEVENS, joined by MR. JUSTICE BRENNAN, MR. JUSTICE STEWART, and MR. JUSTICE BLACKMUN, concluded that the Full Faith and Credit Clause does not preclude successive workmen's compensation awards, since a State has no legitimate interest within the context of the federal system in preventing another State from granting a supplemental compensation award when that second State would have had the power, as here, to apply its workmen's compensation law in the first instance. Pp. 448 U. S. 266-286.
(a) The rule of Industrial Comm'n of Wisconsin v. McCartin, 330 U. S. 622, authorizing a State, by drafting or construing its workmen's compensation statute in "unmistakable language," directly to preclude a compensation award in another State, represents an unwarranted delegation to the States of this Court's responsibility for the final arbitration of full faith and credit questions. To vest the power of determining such extraterritorial effect in the State itself risks the very kind of parochial entrenchment on the interests of other States that it was the purpose of the Full Faith and Credit Clause and other provisions of Art. IV to prevent. A reexamination of McCartin's "unmistakable language" chanrobles.com-red
test reinforces the conclusion that it does not provide an acceptable basis on which to distinguish Magnolia Petroleum Co. v. Hunt, 320 U. S. 430, wherein it was held that the Full Faith and Credit Clause precluded an employee who received a workmen's compensation award for injuries received in one State from seeking supplementary compensation in another State where he had been hired. Pp. 448 U. S. 266-272.
(b) In view, however, of the history of subsequent state cases showing that they overwhelmingly followed McCartin and applied the "unmistakable language" test in permitting successive workmen's compensation awards, the principal values underlying the doctrine of stare decisis would not be served by attempting either to revive Magnolia or to preserve the coexistence of Magnolia and McCartin. The latter attempt could only breed uncertainty and unpredictability, since the application of the "unmistakable language" rule necessarily depends on a determination by one state tribunal of the effect to be given to statutory language enacted by the legislature of a different State. And the former would represent a change that would not promote stability in the law. Moreover, since Magnolia has been so rarely followed, there is little danger that there has been any significant reliance on its rule. Hence, a fresh examination of the full faith and credit issue is appropriate. Pp. 448 U. S. 272-277.
(c) Since petitioner could have sought a compensation award in the first instance in either Virginia or the District of Columbia even if one statute or the other purported to confer an exclusive remedy, respondent and its insurer, for all practical purposes, would have had to measure their potential liability exposure by the more generous of the two workmen's compensation schemes. It follows that a State's interest in limiting the potential liability of businesses within the State is not of controlling importance. Moreover, the state interest in providing adequate compensation to the injured worker would be fully served by the allowance of successive awards. Pp. 448 U. S. 277-280.
(d) With respect to whether Virginia's interest in the integrity of its tribunal's determinations precludes a supplemental award in the District of Columbia, the critical differences between a court of general jurisdiction and an administrative agency with limited statutory authority foreclose the conclusion that constitutional rules applicable to court judgments are necessarily applicable to workmen's compensation awards. The Virginia Industrial Commission, although it could establish petitioner's rights under Virginia law, neither could nor purported to determine his rights under District of Columbia law. Full faith and credit must be given to the determination that the Commission had the authority to make, but need not be given to determinations that it had no power to make. Since it was not requested, and had no authority, to chanrobles.com-red
pass on petitioner's rights under District of Columbia law, there can be no constitutional objection to a fresh adjudication of those rights. While Virginia had an interest in having respondent pay petitioner the amounts specified in its award, allowing a supplementary recovery in the District of Columbia does not conflict with that interest. And whether or not petitioner sought an award from the less generous jurisdiction in the first instance, the vindication of that State's interest in placing a ceiling on employers' liability would inevitably impinge upon the substantial interests of the second jurisdiction in the welfare and subsistence of disabled workers -- interests that a court of general jurisdiction might consider, but which must be ignored by the Virginia Industrial Commission. Pp. 448 U. S. 280-285.
MR. JUSTICE WHITE, joined by MR. CHIEF JUSTICE BURGER and MR. JUSTICE POWELL, concluded that the Virginia Workmen's Compensation Act lacks the "unmistakable language" which McCartin, supra, requires if a workmen's compensation award is to preclude a subsequent award in another State. Pp. 448 U. S. 289-290.
STEVENS, J., announced the judgment of the Court and delivered an opinion, in which BRENNAN, STEWART, and BLACKMUN, JJ., joined. WHITE, J., filed an opinion concurring in the judgment, which BURGER, C.J.,and POWELL, J., joined, post, p. 448 U. S. 286. REHNQUIST, J., filed a dissenting opinion, in which MARSHALL, J., joined, post, p. 448 U. S. 290.