Carroll v. Lanza
Citation: 349 U.S. 408 (1955)
Facts
Carroll, an Arkansas resident, was injured while working in Arkansas on a construction project for a Missouri subcontractor. He obtained a workers’ compensation award in Missouri under Missouri law. He then brought a tort action in Arkansas against the general contractor. The Arkansas court applied Arkansas law rather than limiting him to Missouri’s workers’ compensation exclusive remedy provision.
Issue
Does the Full Faith and Credit Clause require Arkansas to apply Missouri’s workers’ compensation statute and its exclusive-remedy bar to Carroll’s tort suit?
Holding
No. The Supreme Court held that Arkansas was not required by the Full Faith and Credit Clause to give effect to Missouri’s exclusive-remedy provision. Arkansas had legitimate interests in protecting workers injured within its borders and could apply its own law.
Rule
The Full Faith and Credit Clause does not require a state to apply another state’s law when the forum state has its own substantial interest in the matter. A state may apply its own workers’ compensation and tort law to injuries occurring within its territory even when another state has also awarded compensation.
Significance
Carroll v. Lanza illustrates the limits of Full Faith and Credit in the workers’ compensation context and demonstrates that states retain significant latitude to apply their own law when they have meaningful interests at stake. It is often paired with Hughes v. Fetter to show the tension between FF&C obligation and forum interests.