Byrd v. Blue Ridge Rural Electric Cooperative, Inc.

356 U.S. 525 (1958)


Byrd (P) was injured while connecting power lines. P was an employee of a subcontractor of Blue Ridge Electric Cooperative, Inc. (D). P sued D in federal court in South Carolina for negligence under diversity jurisdiction. P was a citizen of North Carolina, and D was a South Carolina corporation. D defended on a South Carolina law that limited P's award to that of workman's compensation and thus precluded a negligence action. There was a factual dispute as to whether P should be considered a statutory South Carolina employee for purposes of Workman’s Compensation. Under South Carolina common law, such an issue was decided by the trial judge, and federal procedural law required the issue to go to the jury. The trial court refused to allow D's defense. P got the verdict. The Fourth Circuit reversed the jury verdict for P. The Supreme Court reversed and remanded the case to the trial court for a new trial allowing the defense and an opportunity to introduce evidence on the question of whether P was a statutory employee. Under South Carolina law, the issue of immunity from negligence was to be tried by a judge. D claimed that despite the Erie doctrine, South Carolina law cannot be allowed to preclude his right to a jury trial.