Travelers Ins. Co. v. Workmen's Comp. App. Bd

Travelers Ins. Co. v. Workmen's Comp. App. Bd. (1967) 68 Cal.2d 7, was an action for workmen's compensation benefits. The plaintiff originally entered into an oral employment contract in California, and later was injured in Utah. (Id. at pp. 9-11.) The plaintiff was entitled to benefits under California's workmen's compensation statute only if he were injured while working under an employment contract that was entered into in California. (Id. at p. 11.) The choice-of-law issues concerned the place of formation of the employment contract, whether an employment agency in Colorado acted as the employer's agent for purposes of transmitting an employment offer to the plaintiff, and whether the parties had rescinded the oral contract and formed a new employment contract in Wyoming. (Ibid.) Travelers decided each of these questions by considering the governmental interests of the states involved, stating, "California has rejected the traditional mechanical solutions to choice-of-law problems and adopted foreign law only when it is appropriate in light of the significant interests in the particular case." (Id. at p. 11, fn. omitted.) Travelers concluded that California had a strong interest in applying its own laws to determine whether an injured Californian was entitled to benefits under the workmen's compensation act and that the other states involved had no significant interest in applying their laws to the dispute. (Id. at pp. 11-14.) The court therefore concluded that California law governed the place-of-contracting, agency, and rescission issues. (Id. at p. 14.)