on the ground that the recovery sought was barred as res judicata by the Texas award which, by virtue of the constitutional command, was entitled in the Louisiana courts to full faith and credit. The District Court overruled the exceptions and gave judgment for the amount of the compensation fixed by the Louisiana statute, after deducting the amount of the Texas payments. The Louisiana Court of Appeal affirmed, 10 So. 2d 109, and the Supreme Court of Louisiana refused writs of certiorari and review for the reason that it found "no error of law in the judgment complained of." We granted certiorari, 319 U. S. 734, because of the importance of the constitutional question presented and to resolve an apparent conflict of the decision below with our decisions in Chicago, R. I. & P. Ry. Co. v. Schendel, 270 U. S. 611, and Williams v. North Carolina, 317 U. S. 287; cf. Alaska Packers Assn. v. Industrial Accident Comm'n, 294 U. S. 532; Pacific Employers Ins. Co. v. Industrial Accident Comm❜n, 306 U.S. 493.

In Texas a compensation award against the employer's insurer (with exceptions not here applicable, cf. Revised

the employer and the employee. La. Gen. Stat., Title 34, Ch. 15, § 4391. Such employees as receive injuries in the course of their employment are entitled to compensation (§ 4392) in specified amounts (§ 4398), unless the contract of employment provides otherwise (§ 4393), whether the injury is or is not due to the fault of the employer (§ 4427). If the employee elects to be covered under the Act, but the employer elects not to be, then in suits by the employee to recover for injuries received in the course of his employment, certain common law defenses are abolished (§ 4394). The compensation award may be fixed by agreement of the parties (§ 4407), or may be obtained by suit in the district court (§ 4408), with right of appeal to the appropriate appellate courts (§ 4409). And as in the present case, the statute is deemed under some circumstances to be applicable to injuries received by the employee without the state. Hargis v. McWilliams Co., 9 La. App. 108, 119 So. 88; Selser v. Bragmans Bluff Lumber Co., 146 So. 690 (La. App.).

Civil Statutes, Art. 8306, § 5) is explicitly made by statute in lieu of any other recovery for injury to the employee, since Art. 8306, § 3 provides that employees subject to the Act "shall have no right of action against their employer or against any agent, servant or employé of said employer for damages for personal injuries. . . but such employés... shall look for compensation solely to the association [the insurer]." A compensation award which has become final "is entitled to the same faith and credit as a judgment of a court." See Ocean Accident & Guarantee Corp. v. Pruitt, 58 S. W. 2d 41, 44-45 (Tex. Comm. App.), holding that an award is res judicata, not only as to all matters litigated, but as to all matters which could have been litigated in the proceeding with respect to the right to compensation for the injury. To the same effect are Traders & General Ins. Co. v. Baker, 111 S. W. 2d 837. 839, 840 (Tex. Comm. App.); Middlebrook v. Texas Indemnity Ins. Co., 112 S. W. 2d 311, 315 (Tex. Civ. App.); cf. Federal Surety Co. v. Cook, 119 Tex. 89, 24 S. W. 2d 394. The Texas Court of Civil Appeals formerly held that a Texas employee could recover compensation of his Texas employer for an injury in another state for which he had already recovered compensation in that state. Texas Employers' Ins. Assn. v. Price, 300 S. W. 667. But in declining to review the case, the Texas Supreme Court expressly pointed out that this ruling had not been challenged, and that it was leaving the question undecided, 300 S. W. 672. The right of a second recovery in such circumstances was promptly abolished by statute. Revised Civil Statutes, Art. 8306, § 19. And under this statute a compensation award may not be had in Texas if the employee has claimed and received compensation for his injury under the laws of another state. Travelers Insurance Co. v. Cason, 132 Tex. 393, 396, 124 S. W. 2d 321.

The Louisiana Court of Appeal recognized that Texas had jurisdiction to award compensation to respondent for the injury received while working for petitioner within the state, and that the award has the same force and effect in Texas as a judgment rendered by a court of competent jurisdiction in that state. But it thought that full faith and credit did not require the Louisiana courts to give effect to the judgment as res judicata because Louisiana, despite the command of the full faith and credit clause, was entitled to give effect to its own statute prescribing compensation for resident employees of a resident employer even though the injury occurred outside the

state.

It does not appear, nor is it contended, that Louisiana more than Texas allows in its own courts a second recovery of compensation for a single injury. The contention is that since Louisiana is better satisfied with the measure of recovery allowed by its own laws, it may deny full faith and credit to the Texas award, which respondent has procured by his election to pursue his remedy in that state. In thus refusing, on the basis of state law and policy, to give effect to the Texas award as a final adjudication of respondent's claim for compensation for his injury suffered in Texas, the Louisiana court ignored the distinction, long recognized and applied by this Court, and recently emphasized in Williams v. North Carolina, supra, 294–296, between the faith and credit required to be given to judgments and that to which local common and statutory law is entitled under hte Constitution and laws of the United States.

In the case of local law, since each of the states of the Union has constitutional authority to make its own law with respect to persons and events within its borders, the full faith and credit clause does not ordinarily require it to substitute for its own law the conflicting law of another state, even though that law is of controlling force in the courts of that state with respect to the same persons and

events. Pink v. A. A. A. Highway Express, 314 U. S. 201, 209-211 and cases cited; Klaxon Co. v. Stentor Co., 313 U. S. 487, 496-498. It was for this reason that we held that the state of the employer and employee is free to apply its own compensation law to the injury of the employee rather than the law of another state where the injury occurred. Alaska Packers Assn. v. Industrial Accident Comm'n, supra, 544–550. And for like reasons we held also that the state of the place of injury is free to apply its own law to the exclusion of the law of the state of the employer and employee. Pacific Employers Ins. Co. v. Industrial Accident Comm'n, supra, 502–505.

But it does not follow that the employee who has sought and recovered an award of compensation in either state may then have recourse to the laws and courts of the other to recover a second or additional award for the same injury. Where a court must make choice of one of two conflicting statutes of different states and apply it to a cause of action which has not been previously litigated, there can be no plea of res judicata. But when the employee who has recovered compensation for his injury in one state seeks a second recovery in another he may be met by the plea that full faith and credit requires that his demand, which has become res judicata in one state, must be recognized as such in every other.

The full faith and credit clause and the Act of Congress implementing it have, for most purposes, placed a judgment on a different footing from a statute of one state, judicial recognition of which is sought in another. Article IV, § 1, of the Constitution commands that "Full Faith and Credit shall be given in each State to the public Acts, Records, and judicial Proceedings of every other State," and provides that "Congress may by general Laws prescribe the Manner in which such Acts, Records, and Proceedings shall be proved, and the Effect thereof." And Congress has provided that judgments "shall have such

Opinion of the Court.

320 U.S.

faith and credit given to them in every court within the United States as they have by law or usage in the courts of the State from which they are taken." Act of May 26, 1790, c. 11, 1 Stat. 122, as amended, 28 U. S. C. § 687.

From the beginning this Court has held that these provisions have made that which has been adjudicated in one state res judicata to the same extent in every other. Hampton v. McConnell, 3 Wheat. 234, 235; Christmas v. Russell, 5 Wall. 290; Fauntleroy v. Lum, 210 U. S. 230; Kenney v. Supreme Lodge, 252 U. S. 411; Milwaukee County v. White Co., 296 U. S. 268; Davis v. Davis, 305 U. S. 32, 40; Titus v. Wallick, 306 U. S. 282, 291–292; Williams v. North Carolina, supra. Even though we assume for present purposes that the command of the Constitution and the statute is not all-embracing, and that there may be exceptional cases in which the judgment of one state may not override the laws and policy of another,* this Court is the final arbiter of the extent of the exceptions. Alaska Packers Assn. v. Industrial Accident Comm'n, supra, 547; Titus v. Wallick, supra, 291. And we pointed out in Williams v. North Carolina, supra, 294– 295, that "the actual exceptions have been few and far between. . . ."

We are aware of no such exception in the case of a money judgment rendered in a civil suit. Nor are we aware of any considerations of local policy or law which could rightly be deemed to impair the force and effect which the full faith and credit clause and the Act of Congress require to be given to such a judgment outside the state of its rendition. Milwaukee County v. White Co., supra, 277, 278.

4 See, e. g., Huntington v. Attrill, 146 U. S. 657; Fall v. Eastin, 215 U. S. 1; Olmsted v. Olmsted, 216 U. S. 386; Converse v. Hamilton, 224 U. S. 243; Hood v. McGehee, 237 U. S. 611; Broderick v. Rosner, 294 U. S. 629, 642; cf. Wisconsin v. Pelican Ins. Co., 127 U. S. 265, 293 with Milwaukee County v. White Co., supra, 278.