Thomas v. Washington Gas Light Co.

Background

A resident of the District of Columbia who worked for a gas company was injured on the job in Arlington, Virginia. He accepted a Virginia Industrial Commission award paying weekly benefits. Years later he asked the District's federal workers' compensation program for additional benefits. The employer argued that, under Virginia law and the Full Faith and Credit provision, the Virginia award barred any second award in another jurisdiction.

Reasoning

The Court asked whether the District was forbidden to give supplemental benefits because it had to honor Virginia's award. The plurality reviewed two earlier Supreme Court cases, overruled Magnolia, and relied on principles that a state compensation board cannot decide rights under another state's law. The Court said full faith and credit requires respect for what Virginia actually decided, including facts and payments, but does not prevent the District from applying its own compensation law and giving a supplemental award with credit for amounts already paid. The Supreme Court reversed the Fourth Circuit and allowed the District award.

Real world impact

The decision lets injured workers in one place seek extra benefits from another place's compensation program when that second forum could have applied its law at the outset. Employers and insurers must account for possible supplemental awards, though prior payments are credited. The ruling changes how states' compensation systems interact and resolves a split in lower courts.

Dissents or concurrances

One Justice agreed with the result but warned the Court's reasoning could let many judgments be relitigated in other forums. Another Justice dissented, arguing the older rule protecting finality of state awards should remain.