Pacific Employers Ins. Co. v. Industrial Acc. Comm'n
United States Supreme Court
306 U.S. 493 (1939)
A Massachusetts-based employee of Dewey & Almy was injured while temporarily working in California, and California's Industrial Accident Commission (plaintiff) awarded him benefits under California's workers' compensation act; the employer's insurer, Pacific Employers (defendant), argued Massachusetts law should instead govern since the employment relationship was based there, but the California Supreme Court ruled for the Commission, reasoning California's own policy interests in in-state injuries would be undermined otherwise.
Whether, where both a forum state's law and a foreign state's law are constitutionally enacted and applicable to the same matter, the forum state may apply its own law when applying the foreign state's law would offend the forum state's policy.