Magnolia Petroleum Co v. Hunt

Decision Date20 December 1943
Docket NumberNo. 29,29
Citation150 A.L.R. 413,64 S.Ct. 208,320 U.S. 430,88 L.Ed. 149
PartiesMAGNOLIA PETROLEUM CO. v. HUNT
CourtU.S. Supreme Court

Messrs. Homer Hendricks, of Washington, D.C., and Cullen R. Liskow, of Lake Charles, La., for petitioners.

Mr. Sullivan H. Hunt, pro se.

[Argument of Counsel from page 431 intentionally omitted] Mr. Chief Justice STONE delivered the opinion of the Court.

The question for decision is whether, under the full faith and credit clause, Art. IV, § 1 of the Constitution of the United States, an award of compensation for personal injury under the Texas Workmen's Compensation Law, Title 130 of the Revised Civil Statutes of Texas, Vernon's Ann.Civ.St. art. 8306 et seq., bars a further recovery of compensation for the same injury under the Louisiana Workmen's Compensation Law, Title 34, Chapter 15 of the Louisiana General Statutes, Act No. 20 of 1914, as amended.

Magnolia Petroleum Company, petitioner here, employed respondent in Louisiana as a laborer in connection with the drilling of oil wells. In the course of his employment respondent, a Louisiana resident, went from Louisiana to Texas, and while working there for petitioner on an oil well, he was injured by a falling drill stem. He sought and procured in Texas an award of compensation for his injury under its Workmen's Compensation Law,1 and petitioner's insurer made payments of compen- sation as required by the statute and the award. The award became final in accordance with the terms of the Texas statute.2

Respondent then brought the present proceeding in the Louisiana District Court to recover compensation for his injury under the Louisiana Workmen's Compensation Law.3 Petitioner 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. 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. The Louisiana Court of Appeal affirmed, 10 So.2d 109, 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.' We granted certiorari, 319 U.S. 734, 63 S.Ct. 1031, because of the importance of the constitutional question presented and to resolve an apparent conflict of the decision below with our decisions in Chicago, R.I. & P.R. Co. v. Schendel, 270 U.S. 611, 46 S.Ct. 420, 70 L.Ed. 757, 53 A.L.R. 1265, and Williams v. North Carolina, 317 U.S. 287, 63 S.Ct. 207, 143 A.L.R. 1273; cf. Alaska Packers Ass'n v. Industrial Accident Commission, 294 U.S. 532, 55 S.Ct. 518, 79 L.Ed. 1044; Pacific Employers Ins. Co. v. Industrial Accident Commission, 306 U.S. 493, 59 S.Ct. 629, 83 L.Ed. 940.

In Texas a compensation award against the employer's insurer (with exceptions not here applicable, cf. Revised Civil Statutes, Art. 8306, § 5) is explicitly made by statute in lieu of any other recovery for injury to the employee, since Art. 8306, § 3 provides that employees subject to the Act 'shall have no right of action against their employer or against any agent, servant or employe of said employer for damages for personal injuries * * * but such employe § * * * shall look for compensation solely to the association (the insurer)'. A compensation award which has become final 'is entitled to the same faith and credit as a judgment of a court.' See Ocean Accident & Guarantee Corp. v. Pruitt, Tex.Com.App., 58 S.W.2d 41, 44, 45, holding that an award is res judicata, not only as to all matters litigated, but as to all matters which could have been litigated in the proceeding with respect to the right to compensation for the injury. To the same effect are Traders & General Ins. Co. v. Baker, Tex.Com.App., 111 S.W.2d 837, 839, 840; Middlebrook v. Texas Indemnity Ins. Co., Tex.Civ.App., 112 S.W.2d 311, 315; cf. Federal Surety Co. v. Cook, 119 Tex. 89, 24 S.W.2d 394. The Texas Court of Civil Appeals formerly held that a Texas employee could recover compensation of his Texas employer for an injury in another state for which he had already recovered compensation in that state. Texas Employers' Ins. Ass'n v. Price, Tex.Civ.App., 300 S.W. 667. But in declining to review the case, the Texas Supreme Court expressly pointed out that this ruling had not been challenged, and that it was leaving the question undecided, 300 S.W. 672. The right of a second recovery in such circumstances was promptly abolished by statute. Revised Civil Statutes, Art. 8306, § 19. And under this statute a compensation award may not be had in Texas if the employee has claimed and received compensation for his injury under the laws of another state. Travelers Ins. Co. v. Cason, 132 Tex. 393, 396, 124 S.W.2d 321.

The Louisiana Court of Appeal recognized that Texas had jurisdiction to award compensation to respondent for the injury received while working for petitioner within the state, and that the award has the same force and effect in Texas as a judgment rendered by a court of competent jurisdiction in that state. But it thought that full faith and credit did not require the Louisiana courts to give effect to the judgment as res judicata because Louisiana, despite the command of the full faith and credit clause, was entitled to give effect to its own statute prescribing compensation for resident employees of a resident employer even though the injury occurred outside the state.

It does not appear, nor is it contended that Louisiana more than Texas allows in its own courts a second recovery of compensation for a single injury. The contention is that since Louisiana is better satisfied with the measure of recovery allowed by its own laws, it may deny full faith and credit to the Texas award, which respondent has procured by his election to pursue his remedy in that state. In thus refusing, on the basis of state law and policy, to give effect to the Texas award as a final adjudication of respondent's claim for compensation for his injury suffered in Texas, the Louisiana court ignored the distinction, long recognized and applied by this Court, and recently emphasized in Williams v. North Carolina, supra, 317 U.S. at pages 294—296, 63 S.Ct. at page 211, 212, 143 A.L.R. 1273, between the faith and credit required to be given to judgments and that to which local common and statutory law is entitled under the Constitution and laws of the United States.

In the case of local law, since each of the states of the Union has constitutional authority to make its own law with respect to persons and events within its borders, the full faith and credit clause does not ordinarily require it to substitute for its own law the conflicting law of another state, even though that law is of controlling force in the courts of that state with respect to the same persons and events. Pink v. A.A.A. Highway Exp., Inc., 314 U.S. 201, 209-211, 62 S.Ct. 241, 246, 247, 86 L.Ed. 152, 137 A.L.R. 957, and cases cited; Klaxon Co. v. Stentor Electric Co., 313 U.S. 487, 496-498, 61 S.Ct. 1020, 1021, 1022, 85 L.Ed. 1477. It was for this reason that we held that the state of the employer and employee is free to apply its own compensation law to the injury of the employee rather than the law of another state where the injury occurred. Alaska Packers Ass'n v. Industrial Accident Commission, supra, 294 U.S. at pages 544-550, 55 S.Ct. at pages 522—525, 79 L.Ed. 1044. And for like reasons we held also that the state of the place of injury is free to apply its own law to the exclusion of the law of the state of the employer and employee. Pacific Employers Ins. Co. v. Industrial Accident Commission, supra, 306 U.S. at pages 502-505, 59 S.Ct. at pages 633, 634, 83 L.Ed. 940.

But it does not follow that the employee who has sought and recovered an award of compensation in either state may then have recourse to the laws and courts of the other to recover a second or additional award for the same injury. Where a court must make choice of one of two conflicting statutes of different states and apply it to a cause of action which has not been previously litigated, there can be no plea of res judicata. But when the employee who has recovered compensation for his injury in one state seeks a second recovery in another he may be met by the plea that full faith and credit requires that his demand, which has become res judicata in one state, must be recognized as such in every other.

The full faith and credit clause and the Act of Congress implementing it have, for most purposes, placed a judgment on a different footing from a statute of one state, judicial recognition of which is sought in another. Article IV, § 1, of the Constitution commands that 'Full Faith and Credit shall be given in each State to the public Acts, Records, and Judicial Proceedings of every other State', and provides that 'Congress may by general Laws prescribe the Manner in which such Acts, Records and Proceedings shall be proved, and the Effect thereof'. And Congress has provided that judgments 'shall have such faith and credit given to them in every court within the United States as they have by law or usage in the courts of the State from which they are taken.' Act of May 26, 1790, c. 11, 1 Stat. 122, as amended, 28 U.S.C. § 687, 28 U.S.C.A. § 687.

From the beginning this Court has held that these provisions have made that which has been adjudicated in one state res judicata to the same extent in every other. Hampton v. McConnell, 3 Wheat. 234, 235, 4 L.Ed. 378; Christmas v. Russell, 5 Wall. 290, 18 L.Ed. 475; Fauntleroy v. Lum, 210 U.S. 230, 28 S.Ct. 641, 52 L.Ed. 1039; Kenney v. Supreme Lodge, 252 U.S. 411, 40 S.Ct. 371, 64 L.Ed. 638, 10 A.L.R. 716; Milwaukee County v. M. E. White Co., 296 U.S. 268, 56 S.Ct. 229, 80...

To continue reading

Request your trial
330 cases
  • J. Aron and Co., Inc. v. Service Transp. Co.
    • United States
    • U.S. District Court — District of Maryland
    • May 11, 1981
    ...the rights of the parties in every other court as in that where the judgment was rendered." Magnolia Petroleum Co. v. Hunt, 320 U.S. 430, 439, 64 S.Ct. 208, 214, 88 L.Ed. 149 (1943) (Stone, C. J.). Coppedge v. Clinton, 72 F.2d 531 (10th Cir. 1934), decided in those halcyon pre-Erie days, ap......
  • The Tax Matters Partner v. USA, Civil Action No. 3:06cv379-HTW-MTP.
    • United States
    • U.S. District Court — Southern District of Mississippi
    • April 30, 2010
    ...noted that, [t]he prohibition against splitting a cause of action is common law doctrine, citing Magnolia Petroleum Co. v. Hunt, 320 U.S. 430, 460-461, 64 S.Ct. 208, 88 L.Ed. 149 (1943). The tax court in Tigers Eye Trading, LLC, further contended that this policy of having a partner raise d......
  • Kremer v. Chemical Construction Corporation
    • United States
    • U.S. Supreme Court
    • May 17, 1982
    ...493, 61 L.Ed. 966 (1917). Section 1738 was enacted to implement the Full Faith and Credit Clause, Magnolia Petroleum Co. v. Hunt, 320 U.S. 430, 437, 64 S.Ct. 208, 212, 88 L.Ed. 149 (1943), and specifically to insure that federal courts, not included within the constitutional provision, woul......
  • United States v. Silliman
    • United States
    • U.S. Court of Appeals — Third Circuit
    • March 25, 1948
    ...Everett, 1909, 215 U.S. 203, 30 S.Ct. 70, 54 L.Ed. 158; see Mr. Justice Black, dissenting in Magnolia Petroleum Co. v. Hunt, 1943, 320 U.S. 430, 450, 457, 64 S.Ct. 208, 88 L.Ed. 149, 150 A.L.R. 413; cf. Riley v. New York Trust Co., 1942, 315 U.S. 343, 350, 62 S.Ct. 608, 86 L.Ed. 885; In re ......
  • Request a trial to view additional results
7 books & journal articles
  • Attack on Doma
    • United States
    • University of Nebraska - Lincoln Nebraska Law Review No. 76, 2021
    • Invalid date
    ...judicial proceedings of the others." Testimony I, supra note 4, at S5931 (statement of Prof. Tribe)(citing Magnolia Petroleum Co. v. Hunt, 320 U.S. 430, 439 (1943)). This is in sharp contrast to the Supreme Court's description of the Full Faith and Credit Clause as a "nationally unifying fo......
  • The meaning of "general laws": the extent of Congress's power under the Full Faith and Credit Clause and the constitutionality of the Defense of Marriage Act.
    • United States
    • University of Pennsylvania Law Review Vol. 145 No. 6, June - June 1997
    • June 1, 1997
    ...because the practical operation of the federal system, which the Constitution designed, demanded it."); Magnolia Petroleum Co. v. Hunt, 320 U.S. 430, 439 (1943) ("The full faith and credit clause ... became a nationally unifying force. It altered the status of the several states as independ......
  • Elizabeth Redpath, Between Judgment and Law: Full Faith and Credit, Public Policy, and State Records
    • United States
    • Emory University School of Law Emory Law Journal No. 62-3, 2013
    • Invalid date
    ...an argument that the holding in “Mills was undoubtedly wrong,” see Whitten, supra note 38, at 468 n.15.See Magnolia Petroleum Co. v. Hunt, 320 U.S. 430, 437–39 (1943) (“From the beginning this Court has held that these provisions [of full faith and credit] have made that which has been adju......
  • Does Heather have two mommies? The importance of full faith and credit recognition for adoptions by same-sex couples.
    • United States
    • Fordham Urban Law Journal Vol. 39 No. 4, May 2012
    • May 1, 2012
    ...if the latter court had jurisdiction to issue that judgment."). (45.) Baker, 522 U.S. at 234 (quoting Magnolia Petroleum Co. v. Hunt, 320 U.S. 430, 438 (46.) Mark D. Rosen, Why the Defense of Marriage Act is Not (Yet?) Unconstitutional: Lawrence, Full Faith and Credit, and the Many Societal......
  • Request a trial to view additional results

VLEX uses login cookies to provide you with a better browsing experience. If you click on 'Accept' or continue browsing this site we consider that you accept our cookie policy. ACCEPT