Byrd v. Blue Ridge Rural Electric Cooperative, Inc.
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| Byrd v. Blue Ridge Rural Electric Cooperative, Inc. | ||||||||||||
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| Argued January 28, 1958 Reargued April 28 – 29, 1958 Decided May 19, 1958 |
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| Court membership | ||||||||||||
| Chief Justice: Earl Warren Associate Justices: Hugo Black, Felix Frankfurter, William O. Douglas, Harold Hitz Burton, Tom C. Clark, John Marshall Harlan II, William J. Brennan, Jr., Charles Evans Whittaker |
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| Case opinions | ||||||||||||
| Majority by: Brennan Joined by: Warren, Black, Douglas, Burton, Clark Concurrence/dissent by: Whittaker Dissent by: Frankfurter Joined by: Harlan Dissent by: Harlan |
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.
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[edit] 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.
[edit] 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.
