Thomas v. Washington Gas Light Co.

Facts

Plaintiff, Thomas, was a District of Colombia resident hired by Defendant, Washington Gas Light Co. (“WGLC”), to perform work Washington, D.C., Virginia, and Maryland. In 1971, Thomas sustained a back injury while working in Virginia. Several weeks later, the Virginia Industrial Commission approved workmen’s compensation benefits for Thomas in the amount of $62 per week. In 1974, Thomas notified the Department of Labor of his intention to seek supplemental compensation under a Washington, D.C. Act. WGLC opposed the claim on the ground that since, as a matter of Virginia law, the Virginia award excluded any other recovery on account of the injury in Virginia, the D.C. obligation to give that award full faith and credit precluded a second, supplemental award in D.C. The administrative law judge agreed with WGLC that the Virginia award must be given res judicata effect in D.C. to the extent that it was res judicata in Virginia. However, he held that the Virginia award did not preclude a further award of compensation in Virginia, and Thomas was awarded permanent total disability benefits payable from the date of his injury with a credit for the amounts previously paid under the Virginia award. The Benefits Review Board upheld the award, but its order was reversed by the U.S. Court of Appeals for the Fourth Circuit, which held that a second and separate proceeding in another jurisdiction upon the same injury is precluded by the Full Faith and Credit Clause. The U.S. Supreme Court granted certiorari.