Alaska Packers Asso. v. Industrial Acci. Com
In Alaska Packers Asso. v. Industrial Acci. Com. (1935) 294 U.S. 532, the court carried this analysis further.
The issue was whether the workers' compensation law of Alaska (then a territory) or that of California governed a claim by an employee of a California business who had sustained a work-related injury while on assignment in Alaska.
The California Supreme Court upheld an award to the employee by the California Industrial Accident Commission under California law.
The United States Supreme Court affirmed that judgment. (294 U.S. at pp. 538-539.)
As to full faith and credit, the court first found that the workers' compensation laws of the two jurisdictions conflicted materially and that both claimed to be compulsory and exclusive on the facts presented. ( Alaska Packers Asso., supra, 294 U.S. at p. 544.)
The court then gave the following general analysis of the problem:
"It has often been recognized by this Court that there are some limitations upon the extent to which a state will be required by the full faith and credit clause to enforce even the judgment of another state, in contravention of its own statutes or policy. In the case of statutes, the extra-state effect of which Congress has not prescribed, where the policy of one state comes into conflict with that of another, the necessity of some accommodation of the conflicting interests of the two states is still more apparent. A rigid and literal enforcement of the full faith and credit clause, without regard to the statute of the forum, would lead to the absurd result that, wherever the conflict arises, the statute of each state must be enforced in the courts of the other, but cannot be in its own. Unless by force of that clause a greater effect is thus to be given to a state statute abroad than the clause permits it to have at home, it is unavoidable that this Court determine for itself the extent to which the statute of one state may qualify or deny rights asserted under the statute of another. The necessity is not any the less whether the statute and policy of the forum is set up as a defense to a suit brought under the foreign statute or the foreign statute is set up as a defense to a suit or proceedings under the local statute. In either case, the conflict is the same. In each, rights claimed under one statute prevail only by denying effect to the other. In both the conflict is to be resolved, not by giving automatic effect to the full faith and credit clause, compelling the courts of each state to subordinate its own statutes to those of the other, but by appraising the governmental interests of each jurisdiction, and turning the scale of decision according to their weight." ( Alaska Packers Asso., supra, 294 U.S. at pp. 546-547 55 S. Ct. at pp. 523-524, 79 L. Ed. at pp. 1051-1052.)
Applying these principles, the court found that California's interest in the present matter outweighed Alaska's:
"The enactment of the present statute of California was within state power and infringes no constitutional provision. Prima facie every state is entitled to enforce in its own courts its own statutes, lawfully enacted. One who challenges that right, because of the force given to a conflicting statute of another state by the full faith and credit clause, assumes the burden of showing, upon some rational basis, that of the conflicting interests involved those of the foreign state are superior to those of the forum. . . . . . . California's interest is sufficient to justify its legislation and is greater than that of Alaska, of which the employee was never a resident and to which he may never return. Nor should the fact that the employment was wholly to be performed in Alaska, although temporary in character, lead to any different result. It neither diminishes the interest of California in giving a remedy to the employee, who is a member of a class in the protection of which the state has an especial interest, nor does it enlarge the interest of Alaska whose temporary relationship with the employee has been severed." ( Alaska Packers Asso., supra, 294 U.S. at pp. 547-550.)