Thomas v. Washington Gas Light Co.

Brief Fact Summary

Thomas (Plaintiff) argued that the obligation of the District of Columbia to give full faith and credit to an award under the Virginia Workmen’s Compensation Act did not prohibit a supplemental award under a similar act.

Synopsis of Rule of Law

The Full Faith and Credit Clause should not be interpreted to prohibit subsequent workmen’s compensation awards.

Facts

Thomas (Plaintiff) received an award of disability benefits in 1971 under the Virginia Workmen’s Compensation Act for injuries suffered in Virginia.  In 1974, Plaintiff, a resident of the District of Columbia, notified the Department of Labor of his intention to seek compensation under the District of Columbia Act.  Washington (Defendant) opposed the request, arguing that the obligation of the District of Columbia to give full faith and credit to the Virginia award barred a supplemental award under the District’s Workmen’s Compensation Act.  The Court of Appeals for the Fourth Circuit, in reversing the decision of the district court, held that a second and separate proceeding in another jurisdiction upon the same injury, after a prior recovery in another state, was precluded by the Full Faith and Credit Clause.  Thomas (Plaintiff) then brought this appeal.

Issue

The Full Faith and Credit Clause should not be interpreted to prohibit subsequent workmen’s compensation awards.

Held

(Stevens, J.)  No.  The Full Faith and Credit Clause should not be interpreted to prohibit subsequent workmen’s compensation awards.  Typically, a workmen’s compensation tribunal may apply only its own state’s law.  The Virginia Commission could and did establish all of Thomas’s (Plaintiff) rights under Virginia law, but it could not claim to determine his rights under the law of the District of Columbia.  A state has no legitimate interest within the context of our federal system in preventing another state from granting a supplemental compensation award when that second state would have had the power to apply its workmen’s compensation law in the first instance.  Reversed.

Dissent

(Rehnquist, J.)  Unless the District of Columbia has an interest in forcing its residents to accept its law regardless of their wishes, the Virginia Commission’s inability to look to District of Columbia law did not impose upon the District of Columbia’s jurisdictional interests.

Concurrence

(White, J.)  There is no reason that a judgment would not be entitled to full res judicata effect under the Full Faith and Credit Clause just because the rendering tribunal was obligated to apply the law of the forum.

Discussion

The majority in this case distinguished and possibly overruled the holding in Industrial Commission of Wisconsin v. McCartin, 330 U.S. 622 (1947), that authorized a state, by drafting or interpreting its legislation in “unmistakable language,†directly to determine the extraterritorial effect of its workmen’s compensation awards.