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Bradford Electric Light Co. v. Clapper | 286 U.S. 145 (1932)

The Constitution requires each state to give full faith and credit to the public acts of other states. In a Constitution granting each state a level of sovereignty, how is that full faith and credit supposed to work? The United States Supreme Court addressed that question in Bradford Electric Light Company versus Clapper.

Vermont’s workers’ compensation act barred employees injured or killed on the job from suing negligent employers for compensation beyond benefits provided in the act. Vermont’s law also provided that all employment contracts made within Vermont were presumed to be subject to this limitation. New Hampshire’s workers’ compensation law, on the other hand, allowed employees or their estates to choose whether to accept workers' compensation benefits or instead sue for common-law tort damages.

The Bradford Electric Light Company, a Vermont corporation doing business in Vermont and New Hampshire, hired Leon Clapper, a Vermont resident, as a lineman. Clapper worked on Bradford’s lines in both states. While working at a Bradford substation in New Hampshire, Clapper was electrocuted and killed.

Jennie Clapper, Leon’s widow and estate administrator, now a New Hampshire resident, sued Bradford for negligence in New Hampshire state court. Bradford removed the matter to federal court due to diversity of citizenship. Bradford then moved to dismiss, asserting that this action was barred by the Vermont workers’ compensation act. The district court denied Bradford’s motion, ruling that the Vermont statute didn’t apply outside Vermont. A jury trial then found for Clapper, awarding four thousand dollars. The First Circuit initially reversed, but on rehearing, affirmed the district court’s judgment. The United States Supreme Court granted cert.

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