Civil Procedure I, Pages 272–274

Byrd v. Blue Ridge Rural Electric Cooperative

Supreme Court of the United States, 1958

Facts:

Plaintiff was injured while on a construction job for defendant. In a federal diversity suit, he sued in tort based on the South Carolina Workmen's Compensation Act.

Procedural History:

Trial court incorrectly interpreted the state statute.

Issue:

Should the issue of immunity be decided by judge or jury on remand?

Rule:

Jury trials are "an essential factor in the process for which the Federal Constitution provides."

Reasoning:

In state court, the issue would be decided by the judge, but the Seventh Amendment puts restrictions on federal courts. While uniformity should be sought, it is not the most important objective.

Holding:

The issue should be decided by a jury. Reversed and remanded.

Takeaways:

  • Federal courts' outcomes do not have to agree with state courts'.
  • Hesch: In addition to the outcome determinative test, to apply state law the court must also find that the state rule is "bound up" with state created rights or obligations. If so, the court must balance the state interest against the federal interest in maintaining the integrity of its court system. However, when balancing, you apply the state rule absent a strong countervailing federal interest.

Keepa – Amazon Price Tracker