Workers’ Compensation · Primary-source case analysis

Alaska Packers: California Could Apply Its Compensation Remedy to an Out-of-State Injury

By Aneeta Mishra and Timothy Chan

Published August 31, 2026

Alaska Packers Association v. Industrial Accident Commission concerned a seasonal worker hired in California for work in Alaska who was injured there and sought California compensation.

California was the place of hiring

The worker entered the employment relationship in California, was transported to remote seasonal work, and was to be paid after returning.

The contract named Alaska law

The agreement purported to make Alaska compensation the exclusive remedy, but that choice did not eliminate California’s independent regulatory interest.

California had a legitimate protective interest

Practical obstacles to pursuing an Alaska claim and the California-centered employment relationship supported use of the California remedy without violating due process.

The award survived constitutional review

The Court affirmed the state award while treating compensation choice of law as dependent on each jurisdiction’s contacts and interests.

Key takeaways

• Document where and how the employment contract was formed.
• Identify every state connected to the worker, employer, and injury.
• Evaluate contractual choice-of-law language against mandatory compensation statutes.
• Analyze current extraterritorial provisions before selecting a forum.