Law School Case Brief
Alaska Packers Ass'n v. Indus. Accident Comm'n - 294 U.S. 532, 55 S. Ct. 518 (1935)
Every state is entitled to enforce in its own courts its own statutes, lawfully enacted. One who challenges that right, because of the force given to a conflicting statute of another state by the full faith and credit clause, assumes the burden of showing, upon some rational basis, that of the conflicting interests involved those of the foreign state are superior to those of the forum.
Palma, a non-resident alien, entered into an employment contract in California whereby he agreed to work for appellant employer during the salmon canning season in Alaska. The contract stated that the parties would be bound by the Alaska worker's compensation law. Palma was injured and applied for benefits upon his return to California. He was awarded compensation under the California worker's compensation law, which the Supreme Court of California affirmed.
Did full faith and credit require that Alaska law be applied?
The United States Supreme Court affirmed the judgment. The Court held that the California statutory requirement that the provisions for compensation be extended to injuries sustained outside the state did not violate due process because California had a legitimate public interest in regulating the employer-employee relationship and in providing a remedy to appellee. The statute was found to have a rational basis and not to involve any arbitrary or unreasonable exercise of state power. The Court held that full faith and credit did not require that Alaska law be applied in this case because Alaska's interests were not superior to those of California.
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