Thomas v. Washington Gas Light Co.

448 U.S. 261 (1980)

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Nature of the Case

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Facts

P is a resident of the District of Columbia and was hired and worked for Gas (D) in the District of Columbia. P worked primarily in the District but also worked in Virginia and Maryland. P sustained a back injury while at work in Virginia. Two weeks later he entered into an 'Industrial Commission of Virginia Memorandum of Agreement as to Payment of Compensation' providing for benefits of $62 per week. Several weeks later the Virginia Industrial Commission approved the agreement and issued its award directing that payments continue 'during incapacity,' subject to various contingencies and changes set forth in the Virginia statute. In 1974, P notified the Department of Labor of his intent to seek compensation under the D.C Act. D argued that the Virginia award excluded any other recovery 'at common law or otherwise' because the District had to give the Virginia award full faith and credit which precluded a second, supplemental award in the District. The Administrative Law Judge agreed D. He held that the Virginia award, by its terms, did not preclude a further award of compensation in Virginia. The Administrative Law Judge agreed D. He held that the Virginia award, by its terms, did not preclude a further award of compensation in Virginia. The Review Board upheld the award. This was reversed by the Court of Appeals for the Fourth Circuit holding that a 'second and separate proceeding in another jurisdiction upon the same injury after a prior recovery in another State is precluded by the Full Faith and Credit Clause.' P appealed and the Supreme Court granted certiorari.