Alaska Packers Ass'n v. Industrial Acc. Comm'n

In May 1932, Palma (plaintiff) entered into an employment contract in California with Alaska Packers Association (APA) (defendant) whereby Palma agreed to perform seasonal work for APA in Alaska. APA promised to transport Palma from California to Alaska and back, at which point Palma would be compensated. Palma was not a resident of California or Alaska. The parties’ contract stipulated that the employment would be subject to the Alaska Workmen’s Compensation Law (Alaska Act). When Palma returned to California in August 1932, he sought compensation from California’s Industrial Accident Commission (Commission) (plaintiff) for injuries sustained in Alaska. The Commission rendered an award to Palma pursuant to the California Workmen’s Compensation Act (California Act). The California Act gave jurisdiction to the Commission over injuries occurring outside California as long as the employment contract was made within California. The California Act also specified that employers could not be exempted from liability thereunder by virtue of any contract, rule, or regulation. APA challenged the Commission’s decision in a California court, alleging that the Commission’s application of the California Act violated the full faith and credit owed to Alaska. The Supreme Court of California upheld the Commission’s decision, declaring that application of the Alaska Act would contravene California public policy. APA filed a petition for certiorari with the United States Supreme Court.