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jurisdictionappeal

willappellee

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Pettus v. American Airlines, Inc., 587 F.2d 627

Facts

George Pettus was injured while working for American Airlines and initially received compensation under the Virginia Workmen's Compensation Act. His benefits were terminated after the Virginia Commission found he unjustifiably refused recommended back surgery. Pettus later filed a claim under the District of Columbia Workmen's Compensation Act, which was initially denied but later awarded by the Benefits Review Board. The case was appealed by American Airlines and its insurance carrier.

While seeking employment in 1969, Pettus was told by a District of Columbia employment agency that American Airlines had job openings.

Issue

Whether the Benefits Review Board was bound by the Virginia Commission's prior ruling denying Pettus further compensation due to res judicata and the Full Faith and Credit Clause.

Rule

The court applied the principles of res judicata and the Full Faith and Credit Clause, which require that a final judgment in one jurisdiction be recognized and enforced in another jurisdiction.

These principles required the Board to abide by the order of the Virginia Commission refusing Pettus further compensation.

Analysis

The court determined that the issues decided by the Virginia Commission were identical to those raised in the District of Columbia proceedings. Since the Virginia Commission had conducted a full and fair adjudication, its decision that Pettus's refusal to undergo surgery was unjustified was conclusive and binding. Therefore, the Benefits Review Board was compelled to give effect to the Virginia judgment.

A review of the record makes plain that the procedures afforded the appellee in Virginia and the proof adduced before the State agency abundantly met this criterion.

Conclusion

The court vacated the Benefits Review Board's award of compensation to Pettus, concluding that the prior decision of the Virginia Commission barred further claims under the District of Columbia law.

The order of the Benefits Review Board awarding compensation to George Pettus will be vacated for the foregoing reasons.

Who won?

American Airlines, Inc. and its employees' compensation insurance carrier prevailed because the court found that the Benefits Review Board was required to honor the Virginia Commission's prior ruling, which denied Pettus further compensation.

We reverse.

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