Bradford Electric Light Co. v. Clapper

Background

An electric company based in Vermont employed a lineman who lived in Vermont. The worker was sent into New Hampshire to fix burned-out fuses and was killed on the job. His widow, acting as administratrix, elected to sue in New Hampshire under that State’s law for damages. The company defended by saying Vermont’s workmen’s compensation law governed the employment and barred any tort suit.

Reasoning

The central question was which State’s law decided the employee’s right to recover: Vermont, where the contract was made and both parties lived, or New Hampshire, where the death occurred. The Court explained that Vermont’s statute created a statutory employment relationship and that parties who become subject to another State’s compensation law carry those substantive rights with them. Applying the Constitution’s command that states give full faith and credit to each other’s public acts, the Court held New Hampshire must recognize the Vermont compensation rule and could not subject the employer to a common-law tort suit in those circumstances. The Court also rejected New Hampshire public-policy objections and found the company’s New Hampshire filing applied only to employees actually employed there.

Real world impact

The ruling means that when employment and residence are rooted in one State, that State’s compensation law can bar tort suits in another State where a worker is injured while temporarily working. This affects employers, interstate workers, and families by reinforcing the reach of home-state compensation schemes. The Court left open different outcomes for cases involving long-term local employment or local residents.

Dissents or concurrances

A concurring Justice agreed with the result but said he would not decide whether the Constitution compels another State to apply the foreign statute; he thought New Hampshire could choose by comity.