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There are some limitations upon the extent to which a state may be required by the full faith and credit clause to enforce even the judgment of another state in contravention of its own statutes or policy. And in the case of statutes, the extrastate effect of which Congress has not prescribed, as it may under the constitutional provision, the conclusion is unavoidable that the full faith and credit clause does not require one state to substitute for its own statute, applicable to persons and events within it, the conflicting statute of another state, even though that statute is of controlling force in the courts of the state of its enactment with respect to the same persons and events.
The employee, who regularly worked at the employer's head office in Massachusetts, was injured while he was temporarily in California on the business of his employer. The employee instituted the present proceeding before the California Commission for the award of compensation under the California Act for injuries received in the course of his employment in that state naming petitioner insurer as insurance carried under that Act. The California Industrial Accident Commission applied the California Workers' Compensation Act, which awarded compensation for injuries suffered by the employee within California, and refused to apply the Massachusetts Workers' Compensation Act, which provided that the Massachusetts Act was the exclusive remedy available to Massachusetts employees. Petitioner sought to set aside the award of compensation, but the petition was denied. Petitioner sought review.
Was the California court precluded from applying its own workmen’s compensation act because of the full faith and credit required by the Constitution to be given to the Massachusetts workmen’s compensation statute?
On review, the Court held that California was not required to give full faith and credit to the Massachusetts Act because the application of the Massachusetts Act would have been obnoxious to California's policy of applying its own provisions for compensation to the exclusion of all others. The Court noted that not only did the California statute conflict with the Massachusetts statute in respect of its application to employees injured in California, but it also expressly provided that no contract, rule or regulation shall exempt the employer from liability for the compensation fixed by the Act.