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Bradford Electric Light Co. v. Clapper

Supreme Court of the United States
286 U.S. 145, 76 L. Ed. 1026, 82 A.L.R. 696 (1932)
ELI5:

Rule of Law:

The Full Faith and Credit Clause of the U.S. Constitution requires a state to recognize and enforce the exclusive remedy provisions of another state's workers' compensation act when the employment contract was made and the employment relationship is centered in that other state, even if the injury occurred within the forum state.


Facts:

  • Bradford Electric Light Co., Inc. (the Company) was a Vermont corporation with its principal place of business in Vermont.
  • Leon J. Clapper, a resident of Vermont, was employed by the Company in Vermont as a lineman.
  • Clapper's employment contract was made in Vermont and required him to perform emergency service in both Vermont and New Hampshire.
  • The Vermont Workmen’s Compensation Act, which both parties had accepted, stated that its remedies were exclusive for injuries received inside or outside the state.
  • Neither the Company nor Clapper filed any statement rejecting the provisions of the Vermont Act.
  • The Company directed Clapper to go to a substation in New Hampshire to restore some burned-out fuses.
  • While performing this temporary work in New Hampshire, Clapper was killed.

Procedural Posture:

  • Jennie M. Clapper, administratrix, filed an action for damages against Bradford Electric Light Co., Inc. in a New Hampshire state court.
  • The Company removed the case to the U.S. District Court for the District of New Hampshire on the basis of diversity of citizenship.
  • In the District Court, the Company asserted the Vermont Workmen's Compensation Act as a special defense and moved to dismiss the action.
  • The District Court denied the motion to dismiss.
  • After three trials, a jury returned a verdict for the plaintiff, and the District Court entered judgment thereon.
  • The Company (appellant) appealed to the U.S. Circuit Court of Appeals, which first reversed the judgment but, upon rehearing, affirmed the judgment of the District Court in favor of Clapper (appellee).
  • The Company petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.

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Issue:

Does the Full Faith and Credit Clause require a New Hampshire court, where a work-related death occurred, to recognize the exclusive remedy provisions of Vermont's workers' compensation statute as a defense to a tort action, when the employment contract was made in Vermont between a Vermont employer and a Vermont resident?


Opinions:

Majority - Mr. Justice Brandeis

Yes. The Full Faith and Credit Clause requires that the Vermont statute be recognized as a defense, barring the New Hampshire tort action. The Vermont Workmen's Compensation Act is a 'public act' that establishes a statutory relationship between the employer and employee, governing their rights and obligations regardless of where an injury occurs. Because the employment contract was made in Vermont between Vermont residents, Vermont law defines the relationship, and its provision for an exclusive remedy must be honored in other states. To refuse to give effect to this substantive defense would subject the defendant to irremediable liability, which the Full Faith and Credit Clause prohibits. New Hampshire's interest in the matter is merely 'casual,' as the employee was not a resident and was not continuously employed there, so its public policy does not override the constitutional command to give credit to Vermont's law.


Concurring - Mr. Justice Stone

I agree with the result but not the reasoning. The decision should rest on principles of comity, not on a constitutional mandate from the Full Faith and Credit Clause. I hesitate to say that the Constitution compels New Hampshire to subordinate its own domestic policy regarding torts committed within its borders to the laws of Vermont. New Hampshire's interest, derived from the commission of the tortious act within its borders, is at least as valid as Vermont's interest, derived from the origin of the employment contract. The Court should assume that New Hampshire courts would choose to apply Vermont law as a matter of judicial courtesy, rather than being forced to do so by the Constitution.



Analysis:

This decision established a significant precedent in conflict of laws, holding that the Full Faith and Credit Clause can compel a state to apply another state's law as a substantive defense, particularly in the context of workers' compensation. It prioritized the law of the state where the employment relationship was created (lex loci contractus) over the law of the state where the injury occurred (lex loci delicti). This ruling strengthened the power of exclusive remedy provisions in workers' compensation statutes across state lines, but its rigid approach would later be challenged by more flexible 'interest analysis' theories in choice-of-law jurisprudence.

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