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Byrd v. Blue Ridge Rural Electric Cooperative

    Brief Fact Summary. Plaintiff Byrd sued his employer, Defendant Blue Ridge Rural Electric Cooperative after he was injured on the job. Defendant moved to dismiss on the grounds that Byrd’s only recourse was to sue under the South Carolina Workmen’s Comp Act.
    Synopsis of Rule of Law. Where there is a strong Federal policy on a procedural issue, a Federal court sitting in diversity will apply the Federal, rather than the State rule.

    Facts. Plaintiff was injured while on a construction job for defendant. He sued in tort law. Defendant Blue Ridge Rural Electric Cooperative alleged that Plaintiff was a “statutory” employee whose exclusive remedy was under the South Carolina Workmen’s Compensation Act. The trial judge made a ruling interpreting the statute based on the facts of the case rather than submit the factual matter to a jury. The Supreme Court of the United States reviewed the case to determine whether the state court trial judge had correctly interpreted the state statute.

    Issue. Whether a Federal court should follow state or Federal practice in determining which issues are decided by the judge and which are proper for the jury.

    Held. The Court reversed and remanded determining that the State court had incorrectly interpreted the statute. There is a strong Federal policy against allowing state rules to disrupt the judge-jury relationship in the federal courts.

    Discussion. The Court was satisfied that risk of reaching a different outcome, by applying federal, rather than state doctrine was not so strong as to override the long- standing federal practice of jury determinations of disputed factual issues. Therefore, where there is a strong federal interest or policy on a given procedural issue, the federal courts will apply the federal rather than the state rule. Thus, in Federal court, the Federal Rules of Civil Procedure will prevail over a contrary State rule.


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