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Bradford Electric Light Co. v. Clapper
United States Supreme Court
286 U.S. 145 (1932)
Leon Clapper, a Vermont resident, was employed by Bradford Electric Light Co. (Bradford) (defendant), which was incorporated and headquartered in Vermont. Bradford managed power lines that extended into New Hampshire. While working on a line in New Hampshire, Clapper was electrocuted. The administrator of his estate (plaintiff) filed a negligence suit against Bradford in a New Hampshire court. New Hampshire law provided that an injured employee could seek recovery pursuant to New Hampshire’s workers’ compensation law or by filing a tort action. Under Vermont law, on the other hand, its workers’ compensation act formed the exclusive remedy for an injured employee, even if the injury occurred out of state, unless the employee and employer had expressly agreed otherwise prior to the accident. No such prior agreement had been made between Clapper and Bradford. The New Hampshire court applied New Hampshire law, and a jury found for Clapper. Bradford petitioned the United States Supreme Court for certiorari, arguing that the New Hampshire court should have recognized Vermont law as a defense pursuant to the Full Faith and Credit Clause.
Rule of Law
Holding and Reasoning (Brandeis, J.)
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