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The Court answered the question of whether, under the full
faith and credit clause, an award of compensation for personal injury under the Texas Workmen’s
Compensation Law barred further recovery of compensation for the same injury under Louisiana Workmen’s
Compensation Law.
Sullivan H. Hunt worked in Louisiana for the Magnolia Petroleum Company. While still employed with
Magnolia, Hunt was injured while working in Texas and Hunt applied for and received an injury award
under the Texas workmen compensation laws. Hunt then applied for an award in Louisiana. Magnolia
attempted to bar Hunt from collecting further award in Louisiana based upon the award received in Texas
(res judicata). The Louisiana District Court allowed the award in Louisiana after first deducting
payments received in Texas. The Louisiana Court of Appeals affirmed and the Supreme Court of Louisiana
refused writs of certiorari.
The U.S. Supreme Court reversed the judgment. The Court agreed that under the full faith and credit
clause, Hunt was barred from pursuing further award.
“And the law of a state is embodied as well in its common law rules as in its statutes.” The
Court cited Erie R.R. Co. v. Tompkins, 304 U.S. 64 (1938) as the
basis of this statement.
Full Text: Magnolia Petroleum Co.
v. Hunt, 320 U.S. 430 (1943) |