Byrd v. Blue Ridge Rural Electrical Cooperative, Inc.
356 U.S. 525, 78 S. Ct. 893, 2 L. Ed. 2d 953 (1958)

  • Byrd was employed as an independent contractor and was injured while working on a project for Blue Ridge. He sued for negligence.
    • Since Byrd was a North Carolina resident and Blue Ridge was incorporated in South Carolina, he sued in Federal Court under diversity jurisdiction.
    • Blue Ridge argued that because Byrd was doing the same work as their regular employees, Byrd was a “statutory employee” and the South Carolina Workmen’s Compensation Act (SCWCA) provided the exclusive remedy.
  • The Federal Trial Court found for Blue Ridge. Byrd appealed.
    • Under South Carolina law, a judge would make the decision, not a jury. The Federal Trial Court followed the South Carolina law and had a Federal judge decide the case.
      • Federal law would have had a jury decide, but since the case was being heard in South Carolina, the Federal Court followed the State rules.
    • Byrd argued that he should have been given a jury trial.
  • The Federal Appellate Court affirmed. Byrd appealed.
  • The US Supreme Court reversed and remanded back to the Federal Trial Court for a jury trial.
    • The US Supreme Court noted that in South Carolina a judge decides whether a plaintiff is covered by the SCWCA but a jury is allowed to decide all other factual issues.
      • The Court found that the system used in South Carolina wasn’t a rule, just a form and mode.
    • The US Supreme Court noted that the outcome determinative test discussed in Guaranty Trust Co. v. York (326 U.S. 9 (1945)), would say that if reaching the same outcome were the only consideration then the Federal court would have to follow State practice.
    • However, the Court found that in this case, following the State practice would disrupt the Federal system of allocating functions between judges and juries. Therefore, State law should not be allowed to interfere with this judge-jury relationship especially considering the 7th Amendment.
      • The 7th Amendment guarantees the right to a jury trial.
      • Constitutional issues always trump any other law.
  • Basically, in this case the Court found that the possibility of a different outcome was less important than preserving the judge-jury function allocations in the Federal system.
    • So the outcome determinative test from Guaranty Trust isn’t an absolute must follow rule.