Workers’ Compensation · Primary-source case analysis

Thomas: Full Faith and Credit Did Not Bar a Supplemental Workers’ Compensation Award

By Aneeta Mishra and Timothy Chan

Published August 10, 2026

Decision: Thomas v. Washington Gas Light Co., 448 U.S. 261 (1980).

Thomas v. Washington Gas Light Co. involved a District of Columbia resident hired there, injured while working in Virginia, and awarded Virginia benefits before obtaining additional benefits under the District’s compensation law with credit for the earlier payments.

Two jurisdictions had substantial connections to the claim

The worker lived and was hired in the District of Columbia, the employer was principally located there, and the injury occurred in Virginia. He first received a Virginia Industrial Commission award and later sought supplemental compensation in the District. The Virginia tribunal adjudicated rights under Virginia law; it did not determine the worker’s separate entitlement under District of Columbia law.

The court of appeals treated the first award as preclusive

The Fourth Circuit concluded that full faith and credit prevented the District from entering a second award because Virginia law described its remedy as exclusive.

The Supreme Court rejected a constitutional bar

A four-Justice opinion concluded that a state lacks a legitimate federal interest in preventing another state with authority over the employment relationship from granting supplemental compensation. Justice White concurred in the judgment on narrower grounds, providing the fifth vote to reverse.

The supplemental award returned for further proceedings

The Court reversed and remanded. The fractured opinions and later statutory developments make present multi-state claims dependent on each jurisdiction’s current coverage, credit, election, and preclusion rules.

Key takeaways

• Map hiring, residence, employer location, injury site, and benefits already paid.
• Preserve the first award, settlement language, and all asserted exclusivity provisions.
• Calculate credits so successive awards do not create double recovery.
• Analyze the controlling opinion and current law in every jurisdiction before filing a second claim.