Workers’ Compensation · Primary-source case analysis

Carroll v. Lanza: The Injury State Could Permit a Tort Remedy Despite Another State’s Compensation Exclusivity

By Aneeta Mishra and Timothy Chan

Published August 29, 2026

Carroll v. Lanza involved a Missouri worker employed by a subcontractor, injured on a project in Arkansas, who received Missouri compensation and then sued the general contractor in Arkansas.

Arkansas was the place of work and injury

The forum had direct authority over safety and injury consequences arising within its territory.

Missouri exclusivity did not control everywhere

Full Faith and Credit did not require Arkansas to import Missouri’s restriction on third-party liability into the Arkansas proceeding.

The forum could provide its own remedy

Arkansas was free to treat the general contractor as a third person subject to suit under its law.

Existing compensation affected recovery mechanics

The litigation required attention to benefits already paid and subrogation rather than an assumption of unrestricted double recovery.

Key takeaways

• Identify the injury state and each contractual employment tier.
• Determine statutory-employer and third-party status in every relevant state.
• Account for compensation liens, credits, and subrogation.
• Use current choice-of-law doctrine and state statutes for modern claims.