448 U.S. 261, 100 S. Ct. 2647 (1980)
Thomas, a resident of the District of Columbia, was hired by respondent Washington Gas Light Co. in the District.1 During the year of his employment he worked primarily in the District but also worked in Virginia and Maryland.2 On January 22, 1971, he sustained a back injury while at work in Arlington, Virginia.3
Two weeks later Thomas entered into an Industrial Commission of Virginia Memorandum of Agreement as to Payment of Compensation providing for benefits of $62 per week.4 Several weeks after that the Virginia Industrial Commission approved the agreement and issued its award directing that payments continue during incapacity, subject to contingencies and changes set forth in the Virginia statute.5
In 1974 Thomas notified the Department of Labor of his intention to seek compensation under the District of Columbia Act.6 Respondent opposed the claim on the ground that the Virginia award precluded any further recovery.7 The Administrative Law Judge held a hearing, took medical evidence, and awarded permanent total disability benefits payable from the date of injury with credit for amounts previously paid under the Virginia award.8 The Benefits Review Board upheld the award.9
The United States Court of Appeals for the Fourth Circuit reversed.10 It held that a second and separate proceeding in another jurisdiction upon the same injury after a prior recovery in another state is precluded by the Full Faith and Credit Clause.11 The Supreme Court granted certiorari.12
Whether the Full Faith and Credit Clause bars the District of Columbia from making a supplemental workers' compensation award after a prior award in Virginia for the same injury?13
The Full Faith and Credit Clause, implemented by 28 U.S.C. § 1738, requires that a state judgment have the same credit, validity, and effect in every other court as it had in the rendering state.14 An administrative workers' compensation award by a tribunal of limited jurisdiction establishes only the measure of rights under the rendering state's law and does not determine rights under another state's law.15
No. Thomas was hired and resided in the District of Columbia, worked primarily there, and sustained his injury in Virginia, yet the Virginia Industrial Commission possessed authority solely to apply Virginia law and issued an award that fixed only his rights under that statute.16 The District of Columbia tribunal could therefore grant a supplemental award of permanent total disability benefits, crediting amounts already paid, without contradicting any factual finding or exceeding the scope of the Virginia determination.17 Because the Virginia Commission lacked power to adjudicate District of Columbia rights, full faith and credit does not preclude the second proceeding.18
The Full Faith and Credit Clause does not bar the supplemental award.19
Related opinions on this issue
Justice White concurred in the judgment.20 He declined to join the plurality's reasoning because it would extend beyond administrative awards to ordinary court judgments.21 White argued that the rationale would undermine the finality purpose of the Full Faith and Credit Clause by allowing plaintiffs a second adjudication whenever the first forum applied its own law.22
He would have retained both Magnolia and McCartin.23 White concluded that McCartin controlled because the Virginia statute lacked the unmistakable language required to preclude a supplemental award.24
Whether Magnolia Petroleum Co. v. Hunt should be overruled?25
Stare decisis does not compel adherence to Magnolia.26 That decision rested on a slim majority and produced an analytically flawed rule that was immediately curtailed by McCartin.27 The attempt to preserve the coexistence of Magnolia and McCartin could only breed uncertainty and unpredictability.28 It conflicts with the principle that a state has no legitimate interest in preventing another state from granting a supplemental compensation award when the second state could have applied its own law in the first instance.29
Yes. Magnolia effected a dramatic change from prior practice and has been followed only rarely.30 After McCartin, its practical scope was reduced to a largely theoretical distinction between unmistakable and ordinary exclusivity language.31 The values of evenhanded and predictable adjudication are better served by overruling Magnolia and permitting successive awards that credit prior payments.32 The second state's interest in worker welfare is not overridden by the first state's interest in limiting employer liability once an award has been entered.33
Magnolia Petroleum Co. v. Hunt is overruled.34
Related opinions on this issue
Joined by Justice Marshall
Justice Rehnquist dissented.35 He contended that Magnolia was correctly decided and that the case presented the same question as Magnolia.36 Rehnquist argued that the plurality's interest-balancing approach improperly distinguished administrative awards from court judgments, overlooking the distinction between faith and credit required for judgments and that for statutes.37
He maintained that Virginia possessed a cognizable interest in the finality of its adjudication and in limiting employer liability after the employer had been haled before its tribunal and adjudged liable.38 Rehnquist concluded that the plurality's rule would create confusion for the many modern tribunals of limited jurisdiction.39 He argued that the Full Faith and Credit Clause did not allot to the Court the task of balancing interests where judicial proceedings of a State were involved.40