Dissell v. Trans World Airlines: Constitutional Limitations on the Workers' Compensation Commission's Subject-Matter Jurisdiction

To rule upon a workers' compensation claim, the Maine Workers' Compensation Commission must determine that it has both personal and subject-matter jurisdiction. Personal jurisdiction is determined by applying Maine's "long-arm" statute. Subject-matter jurisdiction derives from the Commission's status as an administrative agency authorized to administer the Maine Workers' Compensation Act (MWCA). Although subject-matter determination generally involves a choice-of-law issue, in a workers' compensation claim having extraterritorial aspects, the Commission is not free to apply the compensation acts of other states that have contacts with the claim. Rather, the Commission may determine only if it has authority under the MWCA to address the claim. If the Commission decides that it does not have such authority, it must dismiss the claim for lack of subject-matter jurisdiction. Although most states have a provision in their workers' compensation statutes regarding the scope of subject-matter jurisdiction, the MWCA is silent on the extraterritorial limitations of the Act. The Maine Supreme Judicial Court, sitting as the Law Court, has therefore determined that the only limitations placed upon the Commission's subject-matter jurisdiction to hear claims having extraterritorial aspects are the constitutional limits implicit in the Workers' Compensation Act itself. Accordingly, the Maine Workers' Compensation Commission's subject-matter jurisdiction is limited only by the due process clause and the full faith and credit clause of the United States Constitution. In a recent decision, Dissell v. Trans World Airlines, the Law Court held that a claim before the Workers' Compensation Commission satisfied subject-matter jurisdiction requirements solely on the basis of the employee's residence in Maine. By premising subject-matter jurisdiction on this single contact, the Dissell decision expands the subject-matter jurisdiction law of Maine in a noteworthy manner; no other jurisdiction, by statute or judicial decision, has ever determined that it had subject-matter jurisdiction solely on the basis of an employee's residence.