Byrd v. Blue Ridge Rural Electric Cooperative, Inc.

Infobox SCOTUS case
Litigants=Byrd v. Blue Ridge Rural Electric Cooperative, Inc.
ArgueDate=January 28
ArgueYear=1958
ReargueDateA=April 28
ReargueDateB=29
ReargueYear=1958
DecideDate=May 19
DecideYear=1958
FullName=Byrd v. Blue Ridge Rural Electric Cooperative, Incorporated
USVol=356
USPage=525
Citation=78 S. Ct. 893; 2 L. Ed. 2d 953; 1958 U.S. LEXIS 1029
Prior="Certiorari" to the United States Court of Appeals for the Fourth Circuit
Subsequent=
Holding=
SCOTUS=1957-1958
Majority=Brennan
JoinMajority=Warren, Black, Douglas, Burton, Clark
Concurrence/Dissent=Whittaker
Dissent=Frankfurter
JoinDissent=Harlan
Dissent2=Harlan
LawsApplied=

"Byrd v. Blue Ridge Rural Electric Cooperative, Inc.", 356 U.S. 525 (1958), was a decision by the Supreme Court of the United States that refined the doctrine set forth in "Erie Railroad Co. v. Tompkins", regarding in what instances Federal courts were required to follow state law.

Background of the case

The plaintiff in this case was employed as an independent contractor and was injured on the job. The defendant argued that because plaintiff was doing the same work as his regular employees, the plaintiff was a statutory employee and the South Carolina Workmen's Compensation Act provided plaintiff's exclusive remedy.

The Court's decision

The question is whether the plaintiff is covered by the South Carolina Workmen's Compensation Act and therefore is barred from any other remedy against his employer.

The Court, in a majority opinion by Justice William Brennan, first discussed whether the issue should be decided by a jury or by a court. The court notes that while in South Carolina the court decided the question, no reason is given for why the jury is allowed to decide all other factual issues except whether the plaintiff was covered by the South Carolina Workmen's compensation act. The courts say that this requirement is a "form and mode" of enforcing the defendant's immunity from prosecution and not a rule.

The court then discuss the outcome determinative test from Guaranty Trust Co. v. York. The court says that if reaching the same outcome were the only consideration then the federal court would have to follow state practice. However, in this case, following the state practice would disrupt the federal system of allocating functions between judges and juries. The state law should not be allowed to interfere with this judge-jury relationship especially considering the Seventh Amendment to the United States Constitution.

Thus the court found that the possibility of a different outcome was less important than preserving the judge-jury function allocations in the federal system.

ee also

*List of United States Supreme Court cases, volume 356

External links

* [http://caselaw.lp.findlaw.com/scripts/getcase.pl?navby=CASE&court=US&vol=356&page=525 Full text of case from Findlaw.com]