Pacific Employers Ins. Co. v. Industrial Acc. Comm’n

Facts

While in California on company business, a Massachusetts employee of a Massachusetts employer was injured while on the job.  He filed a claim for benefits under the California Workmen’s Compensation Act and was granted the benefits provided by the California Act.  The Industrial Accident Commission of California (Plaintiff) directed that the claimant’s benefits be paid by the employer’s insurance carrier, Pacific Employers Insurance Co. (Defendant).  The company argued that benefits should be awarded on the basis of benefits provided by the Massachusetts workmen’s compensation laws, since the contract of employment was entered into in Massachusetts.  The Massachusetts statutes setting forth the jurisdiction over compensable injuries stated that the employee waived his rights to recover under the laws of another state unless he specifically gave written notice of an election not to waive.  The claimant gave no such notice.  The applicable California statute provided that California would have exclusive jurisdiction over accidents occurring within the state.  Both statutes gave the respective states jurisdiction over injuries outside the state where the contract of hire was entered into within the state.  Pacific Employers (Defendant) argued that the Full Faith and Credit Clause required California to recognize the provisions of the Massachusetts Act.