Mr. Justice STEVENS, joined by Mr. Justice BRENNAN, Mr. Justice STEWART, and Mr. Justice BLACKMUN, concluded that the Full Faith and Credit Clause does not preclude successive workmen's compensation awards, since a State has no legitimate interest within the context of the federal system in preventing another State from granting a supplemental compensation award when that second State would have had the power, as here, to apply its workmen's compensation law in the first instance. Pp. 266-286.

(a) The rule of Industrial Comm'n of Wisconsin v. McCartin, 330 U.S. 622, 67 S.Ct. 886, 91 L.Ed. 1140, authorizing a State, by drafting or construing its workmen's compensation statute in "unmistakable language," directly to preclude a compensation award in another State, represents an unwarranted delegation to the States of this Court's responsibility for the final arbitration of full faith and credit questions. To vest the power of determining such extraterritorial effect in the State itself risks the very kind of parochial entrenchment on the interests of other States that it was the purpose of the Full Faith and Credit Clause and other provisions of Art. IV to prevent. A re-examination of McCartin § "unmistakable language" test reinforces the conclusion that it does not provide an acceptable basis on which to distinguishMagnolia Petroleum Co. v. Hunt, 320 U.S. 430, 64 S.Ct. 208, 88 L.Ed. 149, wherein it was held that the Full Faith and Credit Clause precluded an employee, who received a workmen's compensation award for injuries received in one State, from seeking supplementary compensation in another State where he had been hired. Pp. 266-272.

(b) In view, however, of the history of subsequent state cases showing that they overwhelmingly followed McCartin and applied the "unmistakable language" test in permitting successive workmen's compensation awards, the principal values underlying the doctrine of stare decisis would not be served by attempting either to revive Magnolia or to preserve the coexistence of Magnolia and McCartin. The latter attempt could only breed uncertainty and unpredictability, since the application of the "unmistakable language" rule necessarily depends on a determination by one state tribunal of the effect to be given to statutory language enacted by the legislature of a different State. And the former would represent a change that would not promote stability in the law. Moreover, since Magnolia has been so rarely followed, there is little danger that there has been any significant reliance on its rule. Hence, a fresh examination of the full faith and credit issue is appropriate. Pp. 272-277.

(c) Since petitioner could have sought a compensation award in the first instance in either Virginia or the District of Columbia even if one statute or the other purported to confer an exclusive remedy, respondent and its insurer, for all practical purposes, would have had to measure their potential liability exposure by the more generous of the two workmen's compensation schemes. It follows that a State's interest in limiting the potential liability of businesses within the State is not of controlling importance. Moreover, the state interest in providing adequate compensation to the injured worker would be fully served by the allowance of successive awards. Pp. 277-280.

(d) With respect to whether Virginia's interest in the integrity of its tribunal's determinations precludes a supplemental award in the District of Columbia, the critical differences between a court of general jurisdiction and an administrative agency with limited statutory authority foreclose the conclusion that constitutional rules applicable to court judgments are necessarily applicable to workmen's compensation awards. The Virginia Industrial Commission, although it could establish petitioner's rights under Virginia law, neither could nor purported to determine his rights under District of Columbia law. Full faith and credit must be given to the determination that the Commission had the authority to make but need not be given to determinations that it had no power to make. Since it was not requested, and had no authority, to pass on petitioner's rights under District of Columbia law, there can be no constitutional objection to a fresh adjudication of those rights. While Virginia had an interest in having respondent pay petitioner the amounts specified in its award, allowing a supplementary recovery in the District of Columbia does not conflict with that interest. And whether or not petitioner sought an award from the less generous jurisdiction in the first instance, the vindication of that State's interest in placing a ceiling on employers' liability would inevitably impinge upon the substantial interests of the second jurisdiction in the welfare and subsistence of disabled workers—interests that a court of general jurisdiction might consider, but which must be ignored by the Virginia Industrial Commission. Pp. 280-285.

Mr. Justice WHITE, joined by Mr. Chief Justice BURGER and Mr. Justice POWELL, concluded that the Virginia Workmen's Compensation Act lacks the "unmistakable language" which McCartin, supra, requires if a workmen's compensation award is to preclude a subsequent award in another State. P. 289-290.

James F. Green, Washington, D. C., for petitioner.

Alan I. Horowitz, Washington, D. C., for federal respondent supporting petitioner, pro hac vice, by special leave of Court.

Kevin Jeffrey Baldwin, Washington, D. C., for respondent Washington Gas Light Company.

Mr. Justice STEVENS announced the judgment of the Court and delivered an opinion, in which Mr. Justice BRENNAN, Mr. Justice STEWART, and Mr. Justice BLACKMUN joined.

Petitioner received an award of disability benefits under the Virginia Workmen's Compensation Act. The question presented is whether the obligation of the District of Columbia to give full faith and credit to that award1 bars a supplemental award under the District's Workmen's Compensation Act.2

Petitioner is a resident of the District of Columbia and was hired in the District of Columbia. During the year that he was employed by respondent, he worked primarily in the District but also worked in Virginia and Maryland. He sustained a back injury while at work in Arlington, Va., on January 22, 1971. Two weeks later he entered into an "Industrial Commission of Virginia Memorandum of Agreement as to Payment of Compensation" providing for benefits of $62 per week. Several weeks later the Virginia Industrial Commission approved the agreement and issued its award directing that payments continue "during incapacity," subject to various contingencies and changes set forth in the Virginia statute. App. 49.

In 1974, petitioner notified the Department of Labor of his intention to seek compensation under the District of Columbia Act. Respondent opposed the claim primarily3 on the ground that since, as a matter of Virginia law, the Virginia award excluded any other recovery "at common law or otherwise" on account of the injury in Virginia,4 the District of Columbia's obligation to give that award full faith and credit precluded a second, supplemental award in the District.

The Administrative Law Judge agreed with respondent that the Virginia award must be given res judicata effect in the District to the extent that it was res judicata in Virginia.5 He held, however, that the Virginia award, by its terms, did not preclude a further award of compensation in Virginia.6 Moreover, he construed the statutory prohibition against additional recovery "at common law or otherwise" as merely covering "common law and other remedies under Virginia law."7 After the taking of medical evidence, petitioner was awarded permanent total disability benefits payable from the date of his injury with a credit for the amounts previously paid under the Virginia award. Id., at 31.

The Benefits Review Board upheld the award. 9 BRBS 760 (1978). Its order, however, was reversed by the United States Court of Appeals for the Fourth Circuit, judgment order reported at 598 F.2d 617,8 which squarely held that a "second and separate proceeding in another jurisdiction upon the same injury after a prior recovery in another State [is] precluded by the Full Faith and Credit Clause."9 We granted certiorari, 444 U.S. 962, 100 S.Ct. 447, 62 L.Ed.2d 374, and now reverse.

* Respondent contends that the District of Columbia was without power to award petitioner additional compensation because of the Full Faith and Credit Clause of the Constitution or, more precisely, because of the federal statute implementing that Clause.10 An analysis of this contention must begin with two decisions from the 1940's that are almost directly on point: Magnolia Petroleum Co. v. Hunt, 320 U.S. 430, 64 S.Ct. 208, 88 L.Ed. 149, and Industrial Comm'n of Wisconsin v. McCartin, 330 U.S. 622, 67 S.Ct. 886, 91 L.Ed. 1140.

In Magnolia, a case relied on heavily both by respondent and the Court of Appeals, the employer hired a Louisiana worker in Louisiana. The employee was later injured during the course of his employment in Texas. A tenuous majority11 held that Louisiana was not permitted to award the injured worker supplementary compensation under the Louisiana Act after he had already obtained a recovery from the Texas Industrial Accident Board:

"Respondent was free to pursue his remedy in either state but, having chosen to seek it in Texas, where the award was res judicata, the full faith and credit clause precludes him from again seeking a remedy in Louisiana upon the same grounds." 320 U.S., at 444, 64 S.Ct., at 216.

Little more than three years later, the Court severely curtailed the impact of Magnolia. In McCartin, the employer and the worker both resided in Illinois and entered into an employment contract there for work to be performed in Wisconsin. The employee was injured in the course of that employment. He initially filed a claim with the Industrial Commission of Wisconsin. Prior to this Court's decision in Magnolia, the Wisconsin Commission informed him that under Wisconsin law, he could proceed under the Illinois Workmen's Compensation Act, and then claim compensation under the Wisconsin Act, with credit to be given for any payments made under the Illinois Act. Thereafter, the employer and the employee executed a contract for payment of a specific sum in full settlement of the employee's right under Illinois law. The contract expressly provided, however, that it would " 'not affect any rights that applicant may have under the Workmen's Compensation Act of the State of Wisconsin.' " 330 U.S., at 624, 67 S.Ct., at 888. The employee then obtained a supplemental award from the Wisconsin Industrial Commission; but the Wisconsin state courts vacated it under felt compulsion of the intervening decision in Magnolia.

This Court reversed, holding without dissent12 that Magnolia was not controlling. Although the Court could have relied exclusively on the contract provision reserving the employee's rights under Wisconsin law to distinguish the case from Magnolia, Mr. Justice Murphy's opinion provided a significantly different ground for the Court's holding when it said:

"[T]he reservation spells out what we believe to be implicit in [the Illinois Workmen's Compensation] Act—namely, that an . . . award of the type here involved does not foreclose an additional award under the laws of another state. And in the setting of this case, that fact is of decisive significance." 330 U.S., at 630, 67 S.Ct., at 890.

Earlier in the opinion, the Court had stated that "[o]nly some unmistakable language by a state legislature or judiciary would warrant our accepting . . . a construction" that a workmen's compensation statute "is designed to preclude any recovery by proceedings brought in another state." Id., at 627-628, 67 S.Ct., at 889. The Illinois statute, which the Court held not to contain the "unmistakable language" required to preclude a supplemental award in Wisconsin, broadly provided:

" 'No common law or statutory right to recover damages for injury or death sustained by any employe while engaged in the line of his duty as such employe, other than the compensation herein provided, shall be available to any employe who is covered by the provisions of this act, . . .' " Id., at 627, 67 S.Ct., at 889.

The Virginia Workmen's Compensation Act's exclusive-remedy provision, see n. 4, supra, is not exactly the same as Illinois'; but it contains no "unmistakable language" directed at precluding a supplemental compensation award in another State that was not also in the Illinois Act. Consequently, McCartin by its terms, rather than the earlier Magnolia decision, is controlling as between the two precedents. Nevertheless, the fact that we find ourselves comparing the language of two state statutes, neither of which has been construed by the highest court of either State, in an attempt to resolve an issue arising under the Full Faith and Credit Clause makes us pause to inquire whether there is a fundamental flaw in our analysis of this federal question.

We cannot fail to observe that, in the Court's haste to retreat from Magnolia,13 it fashioned a rule that clashes with normally accepted full faith and credit principles. It has long been the law that "the judgment of a state court should have the same credit, validity, and effect, in every other court in the United States, which it had in the state where it was pronounced." Hampton v. McConnel, 3 Wheat. 234, 235, 4 L.Ed. 378 (Marshall, C. J.). See also Mills v. Duryee, 7 Cranch 481, 484, 3 L.Ed. 411 (Story, J.). This rule, if not compelled by the Full Faith and Credit Clause itself, see n. 18, infra, is surely required by 28 U.S.C. § 1738, which provides that the "Acts, records and judicial proceedings . . . [of any State] shall have the same full faith and credit 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." See n. 1, supra.14 Thus, in effect, by virtue of the full faith and credit obligations of the several States, a State is permitted to determine the extraterritorial effect of its judgment; but it may only do so indirectly by prescribing the effect of its judgments within the State.

The McCartin rule, however, focusing as it does on the extraterritorial intent of the rendering State, is fundamentally different. It authorizes a State, by drafting or construing its legislation in "unmistakable language," directly to determine the extraterritorial effect of its workmen's compensation awards. An authorization to a state legislature of this character is inconsistent with the rule established in Pacific Em- ployers Ins. Co. v. Industrial Accident Comm'n, 306 U.S. 493, 502, 59 S.Ct. 629, 633, 83 L.Ed. 940:

"This Court must determine for itself how far the full faith and credit clause compels the qualification or denial of rights asserted under the laws of one state, that of the forum, by the statute of another state."

It follows inescapably that the McCartin "unmistakable language" rule represents an unwarranted delegation to the States of this Court's responsibility for the final arbitration of full faith and credit questions.15 The Full Faith and Credit Clause "is one of the provisions incorporated into the Constitution by its framers for the purpose of transforming an aggregation of independent, sovereign States into a nation." Sherrer v. Sherrer, 334 U.S. 343, 355, 68 S.Ct. 1087, 1092-93, 92 L.Ed. 1429. To vest the power of determining the extraterritorial effect of a State's own laws and judgments in the State itself risks the very kind of parochial entrenchment on the interests of other States that it was the purpose of the Full Faith and Credit Clause and other provisions of Art. IV of the Constitution to prevent. See Nevada v. Hall, 440 U.S. 410, 424-425, 99 S.Ct. 1182, 1190-1191, 59 L.Ed.2d 416.16

Thus, a re-examination of McCartin's "unmistakable language" test reinforces our tentative conclusion that it does not provide an acceptable basis on which to distinguish Magnolia. But if we reject that test, we must decide whether to overrule either Magnolia or McCartin. In making this kind of decision, we must take into account both the practical values served by the doctrine of stare decisis and the principles that inform the Full Faith and Credit Clause.

The doctrine of stare decisis imposes a severe burden on the litigant who asks us to disavow one of our precedents. For that doctrine not only plays an important role in orderly adjudication;17 it also serves the broader societal interests in evenhanded, consistent, and predictable application of legal rules. When rights have been created or modified in reliance on established rules of law, the arguments against their change have special force.18

It is therefore appropriate to begin the inquiry by considering whether a rule that permits, or a rule that forecloses, successive workmen's compensation awards is more consistent with settled practice. The answer to this question is pellucidly clear.

It should first be noted that Magnolia, by only the slimmest majority, see n. 11, supra, effected a dramatic change in the law that had previously prevailed throughout the United States. See Mr. Justice Black's dissent in Magnolia, 320 U.S., at 457-459, 462, 64 S.Ct., at 222-223, 224.19 Of greater importance is the fact that as a practical matter the "unmistakable language" rule of construction announced in McCartin left only the narrowest area in which Magnolia could have any further precedential value. For the exclusivity language in the Illinois Act construed in McCartin was typical of most state workmen's compensation laws. Consequently, it was immediately recognized that Magnolia no longer had any significant practical impact.20 Moreover, since a state legislature seldom focuses on the extraterritorial effect of its enactments,21 and since a state court has even less occasion to consider whether an award under its State's law is intended to preclude a supplemental award under another State's Workmen's Compensation Act, the probability that any State would thereafter announce a new rule against supplemental awards in other States was extremely remote. As a matter of fact, subsequent cases in the state courts have overwhelmingly followed McCartin and permitted successive state workmen's compensation awards.22 Thus, all that really remained of Magnolia after McCartin was a largely theoretical difference between what the Court described as "unmistakable language" and the broad language of the exclusive-remedy provision in the Illinois Workmen's Compensation Act involved in McCartin.

This history indicates that the principal values underlying the doctrine of stare decisis would not be served either by attempting to revive Magnolia or by attempting to preserve the uneasy coexistence of Magnolia and McCartin. The latter attempt could only breed uncertainty and unpredictability, since the application of the "unmistakable language" rule of McCartin necessarily depends on a determination by one state tribunal of the effect to be given to statutory language enacted by the legislature of a different State. And the former would represent a rather dramatic change that surely would not promote stability in the law. Moreover, since Magnolia has been so rarely followed, there appears to be little danger that there has been any significant reliance on its rule. We conclude that a fresh examination of the full faith and credit issue is therefore entirely appropriate.

Three different state interests are affected by the potential conflict between Virginia and the District of Columbia. Virginia has a valid interest in placing a limit on the potential liability of companies that transact business within its borders. Both jurisdictions have a valid interest in the welfare of the injured employee—Virginia because the injury occurred within that State, and the District because the injured party was employed and resided there. And finally, Virginia has an interest in having the integrity of its formal determinations of contested issues respected by other sovereigns.

The conflict between the first two interests was resolved in Alaska Packers Assn. v. Industrial Accident Comm'n, 294 U.S. 532, 55 S.Ct. 518, 79 L.Ed. 1044, and a series of later cases. In Alaska Packers, California, the State where the employment contract was made, was allowed to apply its own workmen's compensation statute despite the statute of Alaska, the place where the injury occurred, which was said to afford the exclusive remedy for injuries occurring there. Id., at 539, 55 S.Ct., at 520. The Court held that the conflict between the statutes of two States ought not to be resolved "by giving automatic effect to the full faith and credit clause, compelling the courts of each state to subordinate its own statutes to those of the other, but by appraising the governmental interests of each jurisdiction, and turning the scale of decision according to their weight." Id., at 547, 55 S.Ct., at 524.

The converse situation was presented in Pacific Employers Ins. Co. v. Industrial Accident Comm'n, 306 U.S. 493, 59 S.Ct. 629, 83 L.Ed. 940. In that case the injury occurred in California, and the objection to California's jurisdiction was based on a statute of Massachusetts, the State where the employee resided and where the employment contract had been made. The Massachusetts statute provided that the remedy afforded was exclusive of the worker's " 'right of action at common law or under the law of any other jurisdiction.' " Id., at 498, 59 S.Ct., at 631. Again, however, California was permitted to provide the employee with an award under the California statute.23

The principle that the Full Faith and Credit Clause does not require a State to subordinate its own compensation policies to those of another State has been consistently applied in more recent cases. Carroll v. Lanza, 349 U.S. 408, 75 S.Ct. 804, 99 L.Ed. 1183; Crider v. Zurich Ins. Co., 380 U.S. 39, 85 S.Ct. 769, 13 L.Ed.2d 641; Nevada v. Hall, 440 U.S., at 421-424, 99 S.Ct., at 1188-1190. Indeed, in the Nevada case the Court not only rejected the contention that California was required to respect a statutory limitation on the defendant's liability, but did so in a case in which the defendant was the sovereign State itself asserting, alternatively, an immunity from any liability in the courts of California.

It is thus perfectly clear that petitioner could have sought a compensation award in the first instance either in Virginia, the State in which the injury occurred, Carroll v. Lanza, supra; Pacific Employers, supra,24 or in the District of Columbia, where petitioner resided, his employer was principally located, and the employment relation was formed, Cardillo v. Liberty Mutual Ins. Co., 330 U.S. 469, 67 S.Ct. 801, 91 L.Ed. 1028; Alaska Packers Assn. v. Industrial Accident Comm'n, supra. And as those cases underscore, compensation could have been sought under either compensation scheme even if one statute or the other purported to confer an exclusive remedy on petitioner. Thus, for all practical purposes, respondent and its insurer would have had to measure their potential liability exposure by the more generous of the two workmen's compensation schemes in any event. It follows that a State's interest in limiting the potential liability of businesses within the State is not of controlling importance.

It is also manifest that the interest in providing adequate compensation to the injured worker would be fully served by the allowance of successive awards. In this respect the two jurisdictions share a common interest and there is no danger of significant conflict.

The ultimate issue, therefore, is whether Virginia's interest in the integrity of its tribunal's determinations forecloses a second proceeding to obtain a supplemental award in the District of Columbia. We return to the Court's prior resolution of this question in Magnolia.

The majority opinion in Magnolia took the position that the case called for a straightforward application of full faith and credit law: the worker's injury gave rise to a cause of action; relief was granted by the Texas Industrial Accident Board; that award precluded any further relief in Texas;25 and further relief was therefore precluded elsewhere as well. The majority relied heavily on Chicago, R. I. & P. R. Co. v. Schendel, 270 U.S. 611, 46 S.Ct. 420, 70 L.Ed. 757, for the propositions that a workmen's compensation award stands on the same footing as a court judgment, and that a compensation award under one State's law is a bar to a second award under another State's law. See 320 U.S., at 441, 446, 64 S.Ct., at 214, 217.

But Schendel did not compel the result in Magnolia. See 320 U.S., at 448, 64 S.Ct., at 218 (Douglas, J., dissenting); id., at 457, 64 S.Ct., at 222 (Black, J., dissenting).26 In Schendel, the Court held that an Iowa state compensation award, which was grounded in a contested factual finding that the deceased railroad employee was engaged in intrastate commerce, precluded a subsequent claim under the Federal Employers' Liability Act (FELA) brought in the Minnesota state courts, which would have required a finding that the employee was engaged in interstate commerce. Schendel therefore involved the unexceptionable full faith and credit principle that resolutions of factual matters underlying a judgment must be given the same res judicata effect in the forum State as they have in the rendering State. See Durfee v. Duke, 375 U.S. 106, 84 S.Ct. 242, 11 L.Ed.2d 186; Sherrer v. Sherrer, 334 U.S., at 351-352, 68 S.Ct., at 1090-1091. The Minnesota courts could not have granted relief under the FELA and also respected the factual finding made in Iowa.27

In contrast, neither Magnolia nor this case concerns a second State's contrary resolution of a factual matter determined in the first State's proceedings. Unlike the situation in Schendel, which involved two mutually exclusive remedies, compensation could be obtained under either Virginia's or the District's workmen's compensation statutes on the basis of the same set of facts. A supplemental award gives full effect to the facts determined by the first award and also allows full credit for payments pursuant to the earlier award. There is neither inconsistency nor double recovery.

We are also persuaded that Magnolia's reliance on Schendel for the proposition that workmen's compensation awards stand on the same footing as court judgments was unwarranted. To be sure, as was held in Schendel, the factfindings of state administrative tribunals are entitled to the same res judicata effect in the second State as findings by a court. But the critical differences between a court of general jurisdiction and an administrative agency with limited statutory authority forecloses the conclusion that constitutional rules applicable to court judgments are necessarily applicable to workmen's compensation awards.

A final judgment entered by a court of general jurisdiction normally establishes not only the measure of the plaintiff's rights but also the limits of the defendant's liability. A traditional application of res judicata principles enables either party to claim the benefit of the judgment insofar as it resolved issues the court had jurisdiction to decide. Although a Virginia court is free to recognize the perhaps paramount interests of another State by choosing to apply that State's law in a particular case, the Industrial Commission of Virginia does not have that power. Its jurisdiction is limited to questions arising under the Virginia Workmen's Compensation Act. See Va.Code § 65.1-92 (1980). Typically, a workmen's compensation tribunal may only apply its own State's law.28 In this case, the Virginia Commission could and did establish the full measure of petitioner's rights under Virginia law, but it neither could nor purported to determine his rights under the law of the District of Columbia. Full faith and credit must be given to the determination that the Virginia Commission had the authority to make; but by a parity of reasoning, full faith and credit need not be given to determinations that it had no power to make.29 Since it was not requested, and had no authority, to pass on petitioner's rights under District of Columbia law, there can be no constitutional objection to a fresh adjudication of those rights.30

It is true, of course, that after Virginia entered its award, that State had an interest in preserving the integrity of what it had done. And it is squarely within the purpose of the Full Faith and Credit Clause, as explained in Pacific Employers, 306 U.S., at 501, n. 23, supra, 59 S.Ct., at 632, "to preserve rights acquired or confirmed under the public acts" of Virginia by requiring other States to recognize their validity. See n. 23, supra. Thus, Virginia had an interest in having respondent pay petitioner the amounts specified in its award. Allowing a supplementary recovery in the District does not conflict with that interest.

As we have already noted, Virginia also has a separate interest in placing a ceiling on the potential liability of companies that transact business within the State. But past cases have established that that interest is not strong enough to prevent other States with overlapping jurisdiction over particular injuries from giving effect to their more generous compensation policies when the employee selects the most favorable forum in the first instance. Thus, the only situations in which the Magnolia rule would tend to serve that interest are those in which an injured workman has either been constrained by circumstances to seek relief in the less generous forum or has simply made an ill-advised choice of his first forum.

But in neither of those cases is there any reason to give extra weight to the first State's interest in placing a ceiling on the employer's liability than it otherwise would have had. For neither the first nor the second State has any overriding interest in requiring an injured employee to proceed with special caution when first asserting his claim. Compensation proceedings are often initiated informally, without the advice of counsel, and without special attention to the choice of the most appropriate forum. Often the worker is still hospitalized when benefits are sought as was true in this case. And indeed, it is not always the injured worker who institutes the claim. See Schendel, 270 U.S., at 614, 46 S.Ct., at 421.31 This informality is consistent with the interests of both States. A rule forbidding supplemental recoveries under more favorable workmen's compensation schemes would require a far more formal and careful choice on the part of the injured worker than may be possible or desirable when immediate commencement of benefits may be essential.

Thus, whether or not the worker has sought an award from the less generous jurisdiction in the first instance, the vindication of that State's interest in placing a ceiling on employers' liability would inevitably impinge upon the substantial interests of the second jurisdiction in the welfare and subsistence of disabled workers—interests that a court of general jurisdiction might consider, but which must be ignored by the Virginia Industrial Commission. The reasons why the statutory policy of exclusivity of the other jurisdictions involved in Alaska Packers and Pacific Employers, could not defeat California's implementation of its own compensation policies therefore continue to apply even after the entry of a workmen's compensation award.

Of course, it is for each State to formulate its own policy whether to grant supplemental awards according to its perception of its own interests. We simply conclude that the substantial interests of the second State in these circumstances should not be overridden by another State through an unnecessarily aggressive application of the Full Faith and Credit Clause,32 as was implicitly recognized at the time of McCartin.

We therefore would hold that a State has no legitimate interest within the context of our federal system in preventing another State from granting a supplemental compensation award when that second State would have had the power to apply its workmen's compensation law in the first instance. The Full Faith and Credit Clause should not be construed to preclude successive workmen's compensation awards. Accordingly, Magnolia Petroleum Co. v. Hunt should be overruled.

The judgment of the Court of Appeals is reversed, and the case is remanded.

So ordered.

Mr. Justice WHITE, with whom THE CHIEF JUSTICE and Mr. Justice POWELL join, concurring in the judgment.

I agree that the judgment of the Court of Appeals should be reversed, but I am unable to join in the reasoning by which the plurality reaches that result. Although the plurality argues strenuously that the rule of today's decision is limited to awards by state workmen's compensation boards, it seems to me that the underlying rationale goes much further. If the employer had exercised its statutory right of appeal to the Supreme Court of Virginia and that Court upheld the award, I presume that the plurality's rationale would nevertheless permit a subsequent award in the District of Columbia. Otherwise, employers interested in cutting off the possibility of a subsequent award in another jurisdiction need only seek judicial review of the award in the first forum. But if such a judicial decision is not preclusive in the second forum, then it appears that the plurality's rationale is not limited in its effect to judgments of administrative tribunals.

The plurality contends that unlike courts of general jurisdiction, workmen's compensation tribunals generally have no power to apply the law of another State and thus cannot determine the rights of the parties thereunder. Ante, at 282. Yet I see no reason why a judgment should not be entitled to full res judicata effect under the Full Faith and Credit Clause merely because the rendering tribunal was obligated to apply the law of the forum—provided, of course, as was certainly the case here, that the forum could constitutionally apply its law. The plurality's analysis seems to grant state legislatures the power to delimit the scope of a cause of action for federal full faith and credit purposes merely by enacting choice-of-law rules binding on the State's workmen's compensation tribunals. The plurality criticizes theMcCartin case for vesting in the State the power to determine the extraterritorial effect of its own laws and judgments, ante, at 271; yet it seems that its opinion is subject to the same objection. In any event, I am not convinced that Virginia, by instructing its Industrial Commission to apply Virginia law, could be said to have intended that the cause of action which merges in the Virginia judgment would not include claims under the laws of other States which arise out of precisely the same operative facts.

As a matter of logic, the plurality's analysis would seemingly apply to many everyday tort actions. I see no difference for full faith and credit purposes between a statute which lays down a forum-favoring choice-of-law rule and a common-law doctrine stating the same principle. Hence when a court, having power in the abstract to apply the law of another State, determines by application of the forum's choice-of-law rules to apply the substantive law of the forum, I would think that under the plurality's analysis the judgment would not determine rights arising under the law of some other State. Suppose, for example, that in a wrongful-death action the court enters judgment on liability against the defendant, and determines to apply the law of the forum which sets a limit on the recovery allowed. The plurality's analysis would seem to permit the plaintiff to obtain a subsequent judgment in a second forum for damages exceeding the first forum's liability limit.

The plurality does say that factual determinations by a workmen's compensation board will be entitled to collateral-estoppel effect in a second forum. Ante, at 280-281. While this rule does, to an extent, circumscribe the broadest possible implications of the plurality's reasoning, there would remain many cases, such as the wrongful-death example discussed above, in which the second forum could provide additional recovery as a matter of substantive law while remaining true to the first forum's factual determinations. Moreover, the dispositive issues in tort actions are frequently mixed questions of law and fact as to which the second forum might apply its own rule of decision without obvious violation of the principles articulated by four Members of the Court. Actions by the defendant which satisfy the relevant standard of care in the first forum might nevertheless be considered "negligent" under the law of the second forum.

Hence the plurality's rationale would portend a wide-ranging reassessment of the principles of full faith and credit in many areas. Such a reassessment is not necessarily undesirable if the results are likely to be healthy for the judicial system and consistent with the underlying purposes of the Full Faith and Credit Clause. But at least without the benefit of briefs and arguments directed to the issue, I cannot conclude that the rule advocated by the plurality would have such a beneficial impact.

One purpose of the Full Faith and Credit Clause is to bring an end to litigation. As the Court noted in Riley v. New York Trust Co., 315 U.S. 343, 348-349, 62 S.Ct. 608, 86 L.Ed. 885 (1942):

"Were it not for this full faith and credit provision, so far as the Constitution controls the matter, adversaries could wage again their legal battles whenever they met in other jurisdictions. Each state could control its own courts but itself could not project the effect of its decisions beyond its own boundaries."

The plurality's opinion is at odds with this principle of finality. Plaintiffs dissatisfied with a judgment would have every incentive to seek additional recovery elsewhere, so long as the first forum applied its own law and there was a colorable argument that as a matter of law the second forum would permit a greater recovery. It seems to me grossly unfair that the plaintiff, having the initial choice of the forum, should be given the additional advantage of a second adjudication should his choice prove disappointing. Defendants, on the other hand, would no longer be assured that the judgment of the first forum is conclusive as to their obligations, and would face the prospect of burdensome and multiple litigation based on the same operative facts. Such litigation would also impose added strain on an already overworked judicial system.

Perhaps the major purpose of the Full Faith and Credit Clause is to act as a nationally unifying force. Sherrer v. Sherrer, 334 U.S. 343, 355, 68 S.Ct. 1087, 1092, 92 L.Ed. 1429 (1948). The plurality's rationale would substantially undercut that function. When a former judgment is set up as a defense under the Full Faith and Credit Clause, the court would be obliged to balance the various state interests involved. But the State of the second forum is not a neutral party to this balance. There seems to be a substantial danger—not presented by the firmer rule of res judicata—that the court in evaluating a full faith and credit defense would give controlling weight to its own parochial interests in concluding that the judgment of the first forum is not res judicata in the subsequent suit.

I would not overrule either Magnolia or McCartin. To my mind, Mr. Chief Justice Stone's opinion in Magnolia states the sounder doctrine; as noted, I do not see any overriding differences between workmen's compensation awards and court judgments that justify different treatment for the two. However, McCartin has been on the books for over 30 years and has been widely interpreted by state and federal courts as substantially limiting Magnolia. Unlike the plurality's opinion, McCartin is not subject to the objection that its principles are applicable outside the workmen's compensation area. Although I find McCartin to rest on questionable foundations, I am not now prepared to overrule it. And I agree with the plurality that McCartin, rather than Magnolia, is controlling as between the two precedents since the Virginia Workmen's Compensation Act lacks the "unmistakable language" which McCartin requires if a workmen's compensation award is to preclude a subsequent award in another State. I therefore concur in the judgment.

Mr. Justice REHNQUIST, with whom Mr. Justice MARSHALL joins, dissenting.

This is clearly a case where the whole is less than the sum of its parts. In choosing between two admittedly inconsistent precedents, Magnolia Petroleum Co. v. Hunt, 320 U.S. 430, 64 S.Ct. 208, 88 L.Ed. 149 (1943), and Industrial Comm'n of Wisconsin v. McCartin, 330 U.S. 622, 67 S.Ct. 886, 91 L.Ed. 1140 (1947), six of us agree that the latter decision, McCartin, is analytically indefensible. See ante, at 269-272 (plurality opinion); infra, at 291. The remaining three Members of the Court concede that it "rest[s] on questionable foundations." Ante, at 289 (opinion of WHITE, J., joined by BURGER, C. J., and POWELL, J.). Nevertheless, when the smoke clears, it is Magnolia rather than McCartin that the plurality suggests should be overruled. See ante, at 285-286. Because I believe that Magnolia was correctly decided, and because I fear that the rule proposed by the plurality is both ill-considered and ill-defined, I dissent.

In his opinion for the Court in Magnolia, Mr. Chief Justice Stone identified the issue as "whether, under the full faith and credit clause, Art. IV, § 1 of the Constitution of the United States, an award of compensation for personal injury under the Texas Workmen's Compensation Law . . . bars a further recovery of compensation for the same injury under the Louisiana Workmen's Compensation Law . . . ." 320 U.S., at 432, 64 S.Ct., at 210. A majority of this Court answered that inquiry in the affirmative,1 holding that the injured employee "was free to pursue his remedy in either state but, having chosen to seek it in Texas, where the award was res judicata, the full faith and credit clause precludes him from again seeking a remedy in Louisiana upon the same grounds." Id. at 444, 64 S.Ct. at 216. With the substitution of Virginia and the District of Columbia for Texas and Louisiana, this case presents precisely the same question as Magnolia, and, I believe, demands precisely the same answer.

As the plurality today properly notes, Magnolia received rather rough treatment at the hands of a unanimous Court in McCartin, I need not dwell upon the inadequacies of that latter opinion, however, since the plurality itself spotlights those inadequacies quite convincingly. As it observes, McCartin is difficult, if not impossible, to reconcile with "normally accepted full faith and credit principles." Ante, at 270. I also agree completely with the plurality's ultimate conclusion that the rule announced in McCartin "represents an unwarranted delegation to the States of this Court's responsibility for the final arbitration of full faith and credit questions." Ante, at 271.

One might suppose that, having destroyed McCartin's ratio decidendi, the plurality would return to the eminently defensible position adopted in Magnolia. But such is not the case. The plurality instead raises the banner of "stare decisis" and sets out in search of a new rationale to support the result reached in McCartin, significantly failing to even attempt to do the same thing for Magnolia.

If such post hoc rationalization seems a bit odd, the theory ultimately chosen by the plurality is even odder. It would seem that, contrary to the assumption of this Court for at least the past 40 years, a judgment awarding workmen's compensation benefits is no longer entitled to full faith and credit unless, and only to the extent that, such a judgment resolves a disputed issue of fact. I believe that the plurality's justification for such a theory, which apparently first surfaced in a cluster of articles written in the wake of Magnolia,2 does not withstand close scrutiny.

The plurality identifies three different "state interests" at stake in the present case: Virginia's interest in placing a limit on the potential liability of companies doing business in that State, Virginia's interest in the "integrity of its formal determinations of contested issues," and a shared interest of Virginia and the District of Columbia in the welfare of the injured employee. See ante, at 277. The plurality then undertakes to balance these interests and concludes that none of Virginia's concerns outweighs the concern of the District of Columbia for the welfare of petitioner.

Whenever this Court, or any court, attempts to balance competing interests it risks undervaluing or even overlooking important concerns. I believe that the plurality's analysis incorporates both errors. First, it asserts that Virginia's interest in limiting the liability of businesses operating within its borders can never outweigh the District of Columbia's interest in protecting its residents. In support of this proposition it cites Alaska Packers Assn. v. Industrial Accident Comm'n, 294 U.S. 532, 55 S.Ct. 518, 79 L.Ed. 1044 (1935), and Pacific Employers Ins. Co. v. Industrial Accident Comm'n, 306 U.S. 493, 59 S.Ct. 629, 83 L.Ed. 940 (1939). Both of those cases, however, involved the degree of faith and credit to be afforded statutes of one State by the courts of another State. The present case involves an enforceablejudgment entered by Virginia after adjudicatory proceedings. In Magnolia Mr. Chief Justice Stone, who authored both Alaska Packers and Pacific Employers, distinguished those two decisions for precisely this reason, chastising the lower court in that case for overlooking "the distinction, long recognized and applied by this Court, . . . between the faith and credit required to be given to judgments and that to which local common and statutory law is entitled under the Constitution and laws of the United States." 320 U.S., at 436, 64 S.Ct., at 212. This distinction, which has also been overlooked by the plurality here, makes perfect sense, since Virginia surely has a stronger interest in limiting an employer's liability to a fixed amount when that employer has already been haled before a Virginia tribunal and adjudged liable than when the employer simply claims the benefit of a Virginia statute in a proceeding brought in another State.

In a similar vein, the plurality completely ignores any interest that Virginia might assert in the finality of its adjudications. While workmen's compensation awards may be "non-final" in the sense that they are subject to continuing supervision and modification, Virginia nevertheless has a cognizable interest in requiring persons who avail themselves of its statutory remedy to eschew other alternative remedies that might be available to them. Otherwise, as apparently is the result here, Virginia's efforts and expense on an applicant's behalf are wasted when that applicant obtains a duplicative remedy in another State.

At base, the plurality's balancing analysis is incorrect because it recognizes no significant difference between the events that transpired in this case and those that would have transpired had petitioner initially sought his remedy in the District of Columbia. But there are differences. The Commonwealth of Virginia had expended its resources, at petitioner's behest to provide petitioner with a remedy for his injury and a resolution of his "dispute" with his employer. That employer similarly has expended its resources, again at petitioner's behest, in complying with the judgment entered by Virginia. These efforts, and the corresponding interests in seeing that those efforts are not wasted, lie at the very heart of the divergent constitutional treatment of judgments and statutes. Compare Magnolia Petroleum Co. v. Hunt, with Alaska Packers Assn. v. Industrial Accident Comm'n, and Pacific Employers Ins. Co. v. Industrial Accident Comm'n. In this case, of course, Virginia and respondent employer expended very few resources in the administrative process. But that observation lends no assistance to the plurality, which would flatly hold that Virginia has absolutely no power to guarantee that a workmen's compensation award will be treated as a final judgment by other States.

In further support of its novel rule, the plurality attempts to distinguish the judgment entered in this case from one entered by a "court of general jurisdiction." See ante, at 282-283. Specifically, the plurality points out that the Industrial Commission of Virginia, unlike a state court of general jurisdiction, was limited by statute to consideration of Virginia law. According to the plurality, because the Commission "was not requested, and had no authority, to pass on petitioner's rights under District of Columbia law, there can be no constitutional objection to a fresh adjudication of those rights." Ante, at 283. See also ante, at 285.

This argument might have some force if petitioner had somehow had Virginia law thrust upon him against his will. In this case, however, petitioner was free to choose the applicable law simply by choosing the forum in which he filed his initial claim. Unless the District of Columbia has an interest in forcing its residents to accept its law regardless of their wishes, I fail to see how the Virginia Commission's inability to look to district of Columbia law impinged upon that latter jurisdiction's interests. I thus fail to see why petitioner's election, as consummated in his Virginia award, should not be given the same full faith and credit as would be afforded a judgment entered by a court of general jurisdiction.

I suspect that my Brethren's insistence on ratifying McCartin's result despite condemnation of its rationale is grounded in no small part upon their concern that injured workers are often coerced or maneuvered into filing their claims in jurisdictions amenable to their employers. There is, however, absolutely no evidence of such overreaching in the present case. Indeed, had there been "fraud, imposition, [or] mistake" in the filing of petitioner's claim, he would have been permitted, upon timely motion, to vacate the award. See Harris v. Diamond Construction Co., 184 Va. 711, 720, 36 S.E.2d 573, 577 (1946). In this regard, the award received by petitioner is treated no differently than any other judicial award, nor should it be.

There are, of course, exceptional judgments that this Court has indicated are not entitled to full faith and credit. See, e. g., Huntington v. Attrile, 146 U.S. 657, 13 S.Ct. 224, 36 L.Ed. 1123 (1892) (penal judgments); Fall v. Eastin, 215 U.S. 1, 30 S.Ct. 3, 54 L.Ed. 65 (1909) (judgment purporting to convey property in another State). Such exceptions, however, have been "few and far between. . . ." Williams v. North Carolina, 317 U.S. 287, 295, 63 S.Ct. 207, 211, 87 L.Ed. 279 (1942). Furthermore, as this Court noted in Magnolia, there would appear to be no precedent for an exception in the case of a money judgment rendered in a civil suit. See 320 U.S., at 438, 64 S.Ct., at 213. In this regard, there is no dispute that the award authorized by the Industrial Commission of Virginia here is, at least as a matter of Virginia law, equivalent to such a money judgment. See Va.Code §§ 65.1-40, 65.1-100.1 (1980).

I fear that the plurality, in its zeal to remedy a perceived imbalance in bargaining power, would badly distort an important constitutional tenet. Its "interest analysis," once removed from the statutory choice-of-law context considered by the Court in Alaska Packers and Pacific Employers, knows no metes or bounds. Given the modern proliferation of quasi-judicial methods for resolving disputes and of various tribunals of limited jurisdiction, such a rule could only lead to confusion.3 I find such uncertainty unacceptable, and prefer the rule originally announced in Magnolia Petroleum Co. v. Hunt, a rule whose analytical validity is, even yet, unchallenged.

The Full Faith and Credit Clause did not allot to this Court the task of "balancing" interests where the "public Acts, Records, and judicial Proceedings" of a State were involved. It simply directed that they be given the "Full Faith and Credit" that the Court today denies to those of Virginia. I would affirm the judgment of the court below.