Workers’ Compensation · Primary-source case analysis

McCartin: A First Workers’ Compensation Award Did Not Necessarily Bar a Second State’s Award

By Aneeta Mishra and Timothy Chan

Published August 11, 2026

Decision: Industrial Comm’n v. McCartin, 330 U.S. 622 (1947).

Industrial Commission v. McCartin involved an Illinois employment contract, an injury in Wisconsin, an Illinois-approved settlement, and a later claim under Wisconsin’s compensation law.

More than one state had legitimate contacts

Illinois governed the employment relationship while Wisconsin was the place of injury and had its own compensation policy.

The first award lacked unmistakable extraterritorial exclusivity

The Illinois statute and settlement did not clearly foreclose another state from granting supplemental relief under its own law.

Full Faith and Credit did not bar the Wisconsin proceeding

The Court allowed Wisconsin to apply its statute rather than treating the Illinois disposition as universally preclusive.

Credit guarded against double recovery

Amounts already paid under the Illinois award were credited when calculating the Wisconsin recovery.

Key takeaways

• Identify every state with employment and injury contacts.
• Read the first state’s exclusivity language and settlement terms.
• Calculate credit for benefits already paid.
• Check current statutes and Thomas v. Washington Gas Light before relying on McCartin.