U.S. Supreme Court
Magnolia Petroleum Co. v. Hunt, 320 U.S. 430 (1943)
Magnolia Petroleum Co. v. Hunt
Submitted October 20, 1943
Decided December 20, 1943
320 U.S. 430
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. 320 U. S. 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. 320 U. S. 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. 320 U. S. 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. 320 U. S. 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. 320 U. S. 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 chanroblesvirtualawlibrary
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. 320 U. S. 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. 320 U. S. 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. 320 U. S. 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. 320 U. S. 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. 320 U. S. 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. 320 U. S. 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. chanroblesvirtualawlibrary