Conflict of Laws – Full Faith and Credit – Exclusive-Remedy Provision of Foreign Workmen’s Compensation Law

Plaintiff, a resident of Missouri, entered into an employment contract there with a Missouri painting company. He was injured while working in Arkansas on a job his employer had subcontracted from the defendant, a Louisiana contractor. The Missouri employer’s insurer voluntarily began weekly payments to the plaintiff pursuant to the Missouri workmen’s compensation law, although there had been no formal proceeding or award. Payments under the Missouri act were exclusive of all other rights and remedies. After receiving thirty-four payments, the plaintiff sued the defendant for negligence in the Arkansas courts. The defendant had the case removed to the federal district court, where judgment was rendered for the plaintiff. The court of appeals reversed. On certiorari to the United States Supreme Court, held, reversed, three justices dissenting. Arkansas’ interests in the case were substantial in light of possible problems following in the wake of the injury. Therefore, her courts were not bound by the full faith and credit clause to subserve these interests to those of Missouri, despite the exclusive remedy provision of the Missouri law. Carroll v. Lanza, 349 U.S. 408, 75 S.Ct. 804 (1955).