Watson v. Employers Liability Assurance Corporation
United States Supreme Court
348 U.S. 66 (1954)
Toni Company of Illinois (Toni) was a subsidiary of Gillette Safety Razor Company. Toni was headquartered in Massachusetts. Toni manufactured a hair-weaving product for women that contained a dangerous chemical. Employers Liability Assurance Corporation (Assurance) (defendant) issued an insurance policy to Toni in Massachusetts that contained a clause prohibiting direct actions against Assurance until related tort litigation against Toni had been finalized. Mr. and Mrs. Watson (plaintiffs) were residents of Louisiana. Mrs. Watson suffered injuries after using Toni’s hair-weaving product. The Watsons filed suit in Louisiana state court against Assurance. The Watsons argued that, in conflict with Assurance’s contract clause prohibiting their suit until Toni’s liability was determined, Louisiana law permitted direct actions against insurance companies. The matter was removed to federal district court in Louisiana on the basis of diversity jurisdiction. Assurance moved to dismiss the complaint, arguing that the Louisiana law violated the Due Process and Full Faith and Credit Clauses of the United States Constitution. Assurance claimed the laws of Massachusetts or Illinois applied because the contract was formed in those states. The district court agreed and dismissed the complaint. The Watsons appealed. The court of appeals affirmed. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Black, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 174,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.