Texas Employers' Ins. Ass'n v. Hale
James Floyd Hale, an oil field worker, sought compensation under the extra-territorial provisions of the Texas Workmen’s Compensation Act for an injury sustained in New Mexico, claiming he was hired in Texas. The trial court ruled in his favor against the Texas Employers’ Insurance Association. However, the appellate court reversed this judgment, concluding that Hale's employment with Warren and Bradshaw Drilling Company had been terminated before his New Mexico injury, and his subsequent engagement for the New Mexico job did not establish him as a Texas employee for extra-territorial coverage. The court found that the driller lacked authority to guarantee future Texas employment, and merely making a contract in Texas was insufficient for protection under Texas compensation laws when the primary work location was out-of-state.