## Facts

- Kenneth Tator, a Massachusetts resident, worked for Dewey & Almy Chemical Company, a Massachusetts corporation, under a Massachusetts employment contract.
- In September 1935, the employer temporarily sent Tator to its California branch to provide technical assistance.
- Tator was injured in California in the course of his employment.
- Tator sought and obtained an award under California’s workers’ compensation statute from the California Industrial Accident Commission.
- Pacific Employers Insurance Company, the employer’s workers’ compensation carrier, challenged the award, arguing that Massachusetts law provided the exclusive remedy, including for out-of-state injuries, and that California had to respect that exclusivity.
- California courts upheld the award under California law, and the U.S. Supreme Court granted review.

## Issues

1. Whether the Full Faith and Credit Clause required California to apply Massachusetts’ workers’ compensation statute, including its exclusivity and waiver features, to an injury occurring in California.
2. Whether California could constitutionally apply its own workers’ compensation act to a workplace injury within its borders despite a competing, purportedly exclusive, compensation scheme of the state of hiring.

## Decision

- The Supreme Court affirmed the judgment sustaining the California award.
- The Court held that the Full Faith and Credit Clause did not compel California to apply the Massachusetts statute or to treat it as a defense to California compensation.
- California could apply its own workers’ compensation law to an injury suffered within California, even though the employment relationship was centered in Massachusetts and Massachusetts law purported to be exclusive and extraterritorial.
- The Court distinguished Bradford Electric Light Co. v. Clapper and rejected any categorical rule that the state of the employment contract must control in such cases.

## Legal Principles

- Full Faith and Credit does not require a state to substitute another state’s statutes for its own on matters within the forum’s legislative competence.
- A state may apply its workers’ compensation statute to injuries occurring within its territory when the forum has a substantial regulatory interest in the event and its local policy would be frustrated by displacement.
- One state cannot, by declaring its compensation remedy exclusive or by using contractual waiver devices, dictate the choice-of-law outcome in another state’s proceedings.
- In conflicts involving workers’ compensation, constitutional full faith and credit analysis permits accommodation of competing state interests rather than automatic enforcement of another state’s exclusivity provision.

## Conclusion

California was constitutionally permitted to award workers’ compensation for an injury occurring in California and was not required by the Full Faith and Credit Clause to defer to Massachusetts’ purportedly exclusive compensation statute governing the employment relationship.


Pacific Emp. Ins. Co. v. Indus. Accident Comm'n, 306 U.S. 493 (1939)