Alaska Packers Assn. v. Industrial Accident Comm'n of Cal.
294 U.S. 532 · Supreme Court of the United States · 1935
Facts
Palma, hired in California by a California employer for seasonal work in Alaska, was injured there. His contract stipulated Alaska's workers' compensation law would apply. After returning to California, he received an award under California's compensation act, which the employer challenged.
Issue
Does the Due Process Clause or the Full Faith and Credit Clause prevent California from applying its own workers' compensation law to an injury sustained in Alaska, when the employment contract was made in California and stipulated Alaska law?
Holding
No, the Due Process Clause and the Full Faith and Credit Clause do not prevent California from applying its own workers' compensation law. The California Supreme Court's judgment upholding the award was affirmed.
Rule
A state may apply its own workers' compensation law to an out-of-state injury if the employment contract was made within the state, especially when the state has a legitimate governmental interest in protecting its residents or those hired within its borders, and its interest is superior to that of the state where the injury occurred. The Full Faith and Credit Clause does not compel a state to subordinate its own statutes to those of another state when there is a conflict of governmental interests.
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