embers thereof and as such liable
to pay assessments adjudged to be required in liquidation proceedings in
that State, the courts of another State are not required to enforce such
liability against local resident policyholders who did not appear and
were not personally served in the foreign liquidation proceedings; but
are free to decide according to local law the question whether, by
entering into the policies, residents became members of the company.
Again, in State Farm Ins. _v._ Duel,[118] the Court ruled that an
insurance company chartered in State A, which does not treat membership
fees as part of premiums, cannot plead denial of full faith and credit
when State B, as a condition of entry, requires the company to maintain
a reserve computed by including membership fees as well as premiums
received in all States. Were the company's contention accepted, "no
State," the Court observed, "could impose stricter financial standards
for foreign corporations doing business within its borders than were
imposed by the State of incorporation." It is not apparent, the Court
added, that State A has an interest superior to that of State B in the
financial soundness and stability of insurance companies doing business
in State B,--which is obviously more the language of arbitration than of
adjudication, as conventionally regarded.

WORKMEN'S COMPENSATION STATUTES

Finally, the relationship of employer and employee, so far as the
obligations of the one and the rights of the other under workmen's
compensation acts are concerned, has been the subject of similar
treatment. In an earlier case,[119] the cause of action was an injury in
New Hampshire, resulting in death to a workman who had entered the
defendant company's employment in Vermont, the home State of both
parties. The Court held that the case was governed under the full faith
and credit clause by the Vermont workmen's compensation act, not that of
New Hampshire. The relationship, it said, "was created by the law of
Vermont, and so long as that relationship persisted its incidents were
properly subject to regulation there."[120]

However, in an unacknowledged departure from this ruling the Court has
subsequently held that the full faith and credit clause did not preclude
California from disregarding a Massachusetts workmen's compensation
statute and applying its own conflicting act in the case of an injury
suffered by a Massachusetts employee of a Massachusetts employer wh