Bradford Elec. Light Co. v. Clapper

Background

A Vermont utility company employed Leon Clapper, a Vermont resident, as a lineman and sent him temporarily into New Hampshire to fix burned-out fuses. Clapper was killed while working in New Hampshire. His administratrix sued in New Hampshire under that State’s employers’ liability law. The company, a Vermont resident and based in Vermont, defended by saying Vermont’s workmen’s compensation law — which the parties had accepted — replaces tort suits and therefore bars recovery in New Hampshire.

Reasoning

The Court framed the core question as whether the rights between employer and employee should be decided by the law of Vermont, where the contract was made and both parties lived, or by New Hampshire, where the fatal accident occurred. The majority held that Vermont’s statute created the employment relation and its remedies, and that federal full faith and credit requires giving effect to those rights when asserted as a defense in another State’s courts. Because neither party had rejected the Vermont Act, the Court concluded Vermont law governed and reversed the lower court’s judgment for the administratrix.

Real world impact

The ruling means that when an employment relationship is created and centered in one State, that State’s compensation rules can prevent suits in another State for injuries sustained there. The Court noted it did not decide how different facts — for example, a continuous employment in the forum State or local dependents — might affect the outcome.

Dissents or concurrances

Justice Stone concurred but emphasized he would not decide whether the Constitution compels another State to apply the home State’s law; he thought New Hampshire might, by comity, apply Vermont law but should retain its own judgment about forum policy.