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Byrd v. Blue Ridge Rural Electric Cooperative, Inc

    Brief Fact Summary. Byrd (Petitioner), a resident of North Carolina, filed a diversity suit in the District Court for the Western District of South Carolina for injuries allegedly caused by the negligence of Blue Ridge Rural Electric Cooperative, Inc.’s (Respondent), a South Carolina corporation. Petitioner was a lineman in a construction crew of a contractor who had contracted to build power lines for the Respondent. Petitioner was injured while connecting power lines during the course of his employment.

    Synopsis of Rule of Law. There are varying degrees of the Guaranty Trust Co. “outcome-determinative test.” The fact that the decision of which law, federal or state, to apply will should be outcome-determinative is not conclusive. There may be other countervailing considerations.

    Facts. The Respondent offered, as an affirmative defense, that the Plaintiff had the status of a statutory employee under the South Carolina Workmen’s Compensation Act (Act). Therefore, he was barred from suing Respondent at law, so he had to settle for statutory compensation benefits as the sole remedy. At trial, the jury returned a verdict for Petitioner. However, the United States Court of Appeals for the Fourth Circuit reversed, and directed judgment for the Respondent.
    Respondent urged the Supreme Court of the United States to follow the decision rendered by the Supreme Court of South Carolina in Adams v. Davison-Paxon Co., when the court found that it was for the judge, not the jury to decide whether a business owner was a statutory employer.

    Issue. Whether the “outcome-determinative test” as established by the court in Guaranty Trust Co. should apply to the decision of whether to try an issue before a judge or a jury?

    Held. The likelihood of a different result is not so strong as to require the federal court practice of jury determination of disputed factual issues to yield to the state rule in the interest of uniformity of outcome. As a result, the Supreme Court of the United States reversed the decision of the court of appeals and remanded for further proceedings consistent with its opinion.
    This Court in Erie R. Co. v. Tompkins, held that federal courts in diversity suits need to respect the definition of state-created rights and obligations of state courts. Therefore, the Court in this case examined the decision in Adams v. Davison-Paxon Co., to determine whether “it is bound up with these rights and obligations in such a way that its application in the federal court is required.” The rule in South Carolina reflects a policy of allowing the jury to decide all factual issues, except the affirmative defense of immunity. Therefore, the Court concluded that this requirement was merely procedural and was not intended to be “bound up with the definition of the rights and obligations of the parties.”

    The cases following the decision in Erie state that federal courts should conform to state rules even if it is only a procedural rule, when the application of state rules as opposed to federal rules would substantially alter the outcome of the litigation. However, the Court in Herron v. South Pacific Co., 283 U.S. 91 (1931), stated that the application of state rules may not “alter the essential character or function of the federal court.” The Seventh Amendment protection of the right to a jury trial and the prescribed function of the jury is a fundamental right, which should not be governed by state law in federal court.

    The Court concluded that there was not a strong likelihood that a different result would occur in the application of state law, as opposed to federal law. Therefore, the state rule should not be applied over the federal rule in this case.


    Discussion. The decision of whether to try a case before a judge or before a jury is less outcome determinative than, as was the decision in Guaranty Trust Co., to completely bar a suit by an applicable statute of limitations. The decision of whether to try a case before a judge or before a jury is so little outcome-determinative that strong countervailing considerations such a federal policy should compel the district court to refuse to follow the applicable state rule. As a result, the court rejected the “outcome-determinative test” and created a “balance of interests test” in which the federal court weighs whether the state or federal judicial system has the greater interest in having its rule applied to the matter.


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