ile
in California in the course of his employment.[121] The earlier case was
distinguished as not having decided more than that a State statute,
applicable to employer and employee within the State, which provides
compensation if the employee is injured while temporarily in another
State, will be given full faith and credit in the latter when not
obnoxious to its policy. Inasmuch as the Court in the older decision is
reputed to have observed that reliance on the Vermont statute, as a
defense to the New Hampshire suit, was not obnoxious to the policy of
New Hampshire, it may be possible to reconcile these two cases by
stating that a foreign workmen's compensation statute will be recognized
when it is invoked as a defense but need not be applied when the
plaintiff endeavors to found his suit thereon.

Later decisions involving the recognition of a foreign workmen's
compensation act include the following. In Magnolia Petroleum Co. _v._
Hunt[122] the Court ruled that a Louisiana employee of a Louisiana
employer, who is injured on the job in Texas and who receives an award
under the Texas Act, which does not grant further recovery to an
employee who receives compensation under the laws of another State,
cannot obtain additional compensation under the Louisiana Act. However,
a compensation award by State A to a resident employee of a resident
employer injured on the job in State B will not preclude State B from
awarding added compensation under its own laws, when the compensation
statute of State A does not expressly exclude recovery under a law of
the State in which the injury occurred and when the State A award
incorporated a private settlement contract wherein the employee reserved
his rights in State B.[123] Also, the District of Columbia workmen's
compensation act, which expressly covers an employee of the District
employer, "irrespective of the place where the injury occurs,"
constitutionally may be applied, in the case of injury resulting in
death, to a District resident, employed by a District employer, who was
assigned to a job at Quantico, Virginia, and who, for three years prior
to his death in Virginia, has commuted to the job site from his house in
the District.[124]

Development of Section to Date and Possibilities

EVALUATION OF RESULTS

Thus the Court, from according an extrastate operation to statutes and
judicial decisions in favor of defendants in transitory actions,
proceeded next to confer the sa