320 U.S. 430 (1943), 29, Magnolia Petroleum Co. v. Hunt

Docket Nº:No. 29
Citation:320 U.S. 430, 64 S.Ct. 208, 88 L.Ed. 149
Party Name:Magnolia Petroleum Co. v. Hunt
Case Date:December 20, 1943
Court:United States Supreme Court

Page 430

320 U.S. 430 (1943)

64 S.Ct. 208, 88 L.Ed. 149

Magnolia Petroleum Co.



No. 29

United States Supreme Court

Dec. 20, 1943

Submitted October 20, 1943




1. 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 local 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. P. 436.

2. Under the full faith and credit clause, judgments are, for most purposes, upon a footing different from the local law of a State when judicial recognition of either is sought in another State. P. 437.

3. With few exceptions, the full faith and credit clause renders that which has been adjudicated in one State res judicata to the same extent in every other. P. 438.

When a state court refuses credit to the judgment of a sister State, an asserted federal right is denied, and the sufficiency of the grounds of denial are for this Court to determine. P. 443.

These results flow from the unifying purpose of the full faith and credit clause to give nationwide effect to rights judicially established in any part of the nation. P. 439.

4. Respondent, resident in Louisiana and there employed by petitioner, was injured in Texas in the course of his employment. Respondent sought and was awarded compensation under the Texas Workmen's Compensation Law. Payments were made as required by the award, which became final. In Texas, a compensation award which has become final is res judicata, and is entitled to the same faith and credit as a judgment of a court, and an award may not be had when an employee has

Page 431

sought and received for his injury compensation under the laws of another State. Respondent later brought suit in a Louisiana court for a further recovery under the Louisiana Workmen's Compensation Law, and obtained a judgment against the employer for the amount of compensation fixed by that law, less the amount received under the Texas award.


(1) Under the full faith and credit clause, the Texas compensation award was a bar to recovery in the Louisiana proceeding. Chicago, R. I. & P. Ry. Co. v. Schendel, 270 U.S. 611, followed. P. 441.

(2) The interest of Louisiana in awarding compensation to Louisiana employees who are injured out of the State -- vis-a-vis the interest of Texas in awarding compensation for an injury occurring within its borders -- is not sufficient to permit it to ignore the bar of the Texas award. P. 440.

(3) The liability established by the Louisiana judgment is not reconcilable with the rights conferred on the employer by the Texas award and the full faith and credit clause. P. 442.

(4) Whether the proceeding before the Texas board be regarded as a "judicial proceeding" or its award is a "record" within the meaning of the full faith and credit clause and the Act of Congress implementing it, both judicial proceedings and records are required to be given full faith and credit. P. 443.

(5) The suggestion that the Texas award does not bar the recovery in Louisiana because the employee's suit there was on a different cause of action is untenable. P. 443.

It is unnecessary to decide what effect would be required to be given to the Texas award if, under Texas law, an award of compensation in another State would not bar an award in Texas. P. 443.

10 So.2d 109 reversed.

Certiorari, 319 U.S. 734, to review the affirmance of a judgment for the plaintiff in a suit by an employee against an employer to recover compensation for an injury received in the course of the employment. The highest court of the State refused writs of certiorari and review.

Page 432

STONE, J., lead opinion

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, 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.

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 compensation

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as required by the statute and the award. The award became final in accordance with the terms of the Texas statute.2

[64 S.Ct. 211] 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

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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, 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. Ry. Co. v. Schendel, 270 U.S. 611, and Williams v. North Carolina, 317 U.S. 287; cf. Alaska Packers Assn. v. Industrial Accident Comm'n, 294 U.S. 532; Pacific Employers Ins. Co. v. Industrial Accident Comm'n, 306 U.S. 493.

In Texas, a compensation award against the employer's insurer (with exceptions not here applicable, cf. Revised

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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 employee of said employer for damages for personal injuries . . . but such employees . . . 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, 58 S.W.2d 41, 44, 45, [64 S.Ct. 212] 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, 111 S.W.2d 837, 839, 840; Middlebrook v. Texas Indemnity Ins. Co., 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. Assn. v. Price, 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.

Page 436

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, 294-296, 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...

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