Tidewater Oil Company, a Corporation v. Dennis F. Waller

BREITENSTEIN, Circuit Judge

(dissenting).

Waller worked for Spartan under an employment contract made in Oklahoma. Spartan, which makes mobile homes, sent a crew, including Waller, to Turkey to repair mobile homes of a pipe line company. In Turkey, Waller’s superior, acting on behalf of Spartan, contracted with Tidewater for the repair of mobile homes at an isolated location where Tidewater was engaged in oil exploration and production. An airplane, owned and operated by Tidewater, crashed on landing when taking Waller to the site in Turkey where the repair work was to be done. Waller received injuries for which he seeks recovery from Tidewater on the grounds that Tidewater was negligent in the operation of the airplane and in the construction of the runway provided for landing.

The case was filed in an Oklahoma state court and removed to federal court because of diversity. The trial proceeded on the agreed theory that Turkish tort law was the same as that of Oklahoma. The sufficiency of the evidence to sustain the tort liability of Tidewater is not questioned. The query is whether the suit may be maintained in Oklahoma.

Waller was not an employee of Tidewater. The Turkish contract was not a contract of employment but rather a contract between Tidewater and Spartan for specific work with payment therefor made to Spartan. The only pertinence of the Turkish contract is to the question of the secondary liability of Tidewater under the Oklahoma Workmen’s Compensation Law, and that question arises only in the determination of the right of Waller to maintain this suit in Oklahoma.

A federal court sitting in Oklahoma follows the Oklahoma conflict of laws rule.1 Oklahoma will not enforce a con*644tract violative of its own public policy.2 I assume that Oklahoma will follow the same rule in tort cases because the general rule is that foreign law, or rights based thereon, will not be given effect contrary to the settled public policy of the forum.3

The Oklahoma Workmen’s Compensation Law provides an exclusive remedy for the liability of an employer except in circumstances not here material.4 The courts have construed that act as also providing an exclusive remedy against those secondarily liable for a worker’s injuries.5 Secondary liability arises when the injury occurs in the course of the performance of hazardous work for the principal and when that work is “necessarily connected with, and incident to the business of the principal employer.” At the isolated location where this accident happened, Tidewater had to maintain living quarters for its workers and the repair of such quarters was necessarily connected with, and incidental to the business of Tidewater. Under Oklahoma law, Tidewater was secondarily liable and the compensation remedy was exclusive unless the Oklahoma law was changed by the 1955 amendment to § 4 of the state compensation law.6

Prior to the 1955 amendment the Oklahoma compensation law did not cover injuries received in accidents occurring outside of Oklahoma. The amendment made it applicable to such injuries and permitted an injured employee, working under an Oklahoma employment contract, to elect to proceed under the law of the state in which the accident occurred or under the Oklahoma law. The first sentence of the amendment provides that all provisions of the compensation law apply “irrespective of where accident resulting in injury may occur.” The second sentence covers the right of election. The third sentence reads:

“Such right of election shall, however, not preclude the injured employee from recovering any benefits or compensation provided under any law of the State where injury occurred, and if such action be so commenced in such other state, or under the law of another state, and is prosecuted to final determination, such employee shall thereupon be precluded from his right of action under the laws of this State.”

In Groendyke Transport, Inc. v. Gardner, Old., 353 P.2d 695, 698, the Oklahoma Supreme Court held that the third sentence of the 1955 amendment “refers only to claims under the compensation laws and has no relationship to actions at law for damages caused by third persons.” 7 So construed, the third sentence does not change the Oklahoma policy as to the exclusiveness of the compensation law remedy. The generality of the first sentence retains that exclusiveness as Oklahoma policy. The majority opinion in this case collides directly with the rule that a cause of action created by the law of a foreign state or country cannot be enforced in another state or country contrary to the public policy of the forum.8

If the majority opinion is correct in holding that the third sentence of the 1955 amendment permits recovery in Oklahoma under the general laws, rather than the compensation laws, of ’"'e state where the accident occurred, then an employer may be sued in Oklahoma under the general tort laws of the state where*645in an accident occurred injuring his employee and that employer is without the protection of the exclusive remedy provision of the Oklahoma compensation law. I am convinced that this violates the construction placed on the 1955 amendment in the Groendyke case. Accordingly, I would reverse the judgment with direction to dismiss the action. Waller has his remedy under the Oklahoma Workmen’s Compensation Law.

. Klaxon Company v. Stentor Electric Manufacturing Company, 313 U.S. 487, 496, 61 S.Ct. 1020, 85 L.Ed. 1477.

. Klein v. Keller, 42 Okl. 592, 141 P. 1117.

. Restatement, Conflict of Laws, p. 731, § 612; 15 C.J.S. Conflict of Laws § 4(c) (4) (a).

. 85 Okl.St.Ann. § 12 (1951).

. See Burk v. Cities Service Oil Company of Delaware, 10 Cir., 266 F.2d 433 and the Oklahoma cases there cited.

. 85 O.S.Supp.1955, § 4.

. Even if this statement of the Oklahoma Supreme Court is dictum, it is binding on us. Hawks v. Hamill, 288 U.S. 52, 56-59, 53 S.Ct. 240, 77 L.Ed. 610; Whitaker v. Texaco, Inc., 10 Cir., 283 F.2d 169, 174.

. See Urda v. Pan American World Airways, 5 Cir., 211 F.2d 713, and cases there cited.