## Facts

- Halley I. Thomas, a District of Columbia resident, was hired by Washington Gas Light Company in the District of Columbia.
- Thomas was injured while working in Virginia.
- Thomas obtained a disability benefits award from the Virginia Industrial Commission under the Virginia workers’ compensation statute.
- Virginia law treated the Virginia award as excluding other recovery for the same injury.
- Thomas later sought and received a supplemental workers’ compensation award under the District of Columbia workers’ compensation statute.
- The employer argued the Full Faith and Credit Clause required the District of Columbia to treat the Virginia award as barring the supplemental award.

## Issues

1. Whether the Full Faith and Credit Clause prohibits a second jurisdiction from granting a supplemental workers’ compensation award after an earlier award in another state that purports to bar further recovery for the same injury.
2. Whether the first state’s compensation award must be given preclusive effect to foreclose application of the second jurisdiction’s workers’ compensation law.
3. What effect, if any, res judicata principles require a second jurisdiction to give to factual findings made in the first jurisdiction’s administrative compensation proceeding.

## Decision

- The Supreme Court reversed the judgment that had set aside the District of Columbia award and remanded.
- The Court held that the Full Faith and Credit Clause does not preclude successive workers’ compensation awards when the second jurisdiction could have applied its compensation law in the first instance.
- The Court reasoned that the first state has no legitimate interest, within the federal system, in preventing another competent jurisdiction from granting a supplemental award.
- The Court rejected the view that a state may, through “unmistakable language” in its compensation statute or its construction, constitutionally preclude a later supplemental award in another jurisdiction.
- The Court distinguished (a) the required respect for the first tribunal’s factfinding and adjudication of rights under its own law from (b) a constitutional bar against the second jurisdiction applying its own law to grant additional compensation.

## Legal Principles

- The Full Faith and Credit Clause does not bar a supplemental workers’ compensation award by a second jurisdiction that has sufficient contacts and authority to apply its law to the employment relationship or injury.
- A first state’s compensation award determines rights under that state’s law but does not determine rights under a different jurisdiction’s compensation statute.
- Factual findings of state administrative tribunals are entitled to the same res judicata effect in a later proceeding as judicial findings, but such preclusion does not automatically foreclose application of another jurisdiction’s law.
- A state may prescribe the effect of its judgments within its own territory, but it cannot constitutionally dictate the extraterritorial effect of its compensation award so as to block another competent jurisdiction’s supplemental relief.
- Overlapping state interests in multi-jurisdiction employment relationships permit more than one jurisdiction to apply workers’ compensation law, subject to mechanisms that avoid double recovery.

## Conclusion

The Court held that a prior workers’ compensation award in one state does not, by full faith and credit alone, prevent a second jurisdiction with authority to apply its own workers’ compensation law from granting a supplemental award for the same injury, though the first proceeding’s factual determinations may carry preclusive effect.


Thomas v. Wash. Gas Light Co., 448 U.S. 261 (1980)