Friday, December 6, 2013

Byrd v. Blue Ridge Rural Electric Cooperative case brief

Byrd v. Blue Ridge Rural Electric Cooperative case brief summary
356 U.S. 525 (1958)


CASE SYNOPSIS
Certiorari was granted to the United States Court of Appeals for the Fourth Circuit to determine whether the court of appeals erred in directing judgment for respondent corporation in a negligence action and to determine whether petitioner was entitled to a jury trial.

CASE FACTS
Petitioner was employed by a construction company that had contracted with respondent corporation to build power lines and stations. Petitioner was injured while working and brought a negligence suit against respondent. Respondent claimed that petitioner's exclusive remedy was under the South Carolina Workmen's Compensation Act. The court of appeals directed judgment for respondent.

DISCUSSION

  • The Supreme Court reversed and remanded. 
  • The Court upheld the court of appeals' interpretation of S.C. Code Ann. § 72-111, but held that petitioner should have an opportunity to offer his own proof under that interpretation of the statute. 
  • The Court also held that petitioner was entitled to a jury trial, even though under South Carolina law petitioner would not have been entitled to a jury trial on this issue. 
  • The Court stated that it did not believe that the likelihood of a different result was so strong as to require the federal practice of jury determination of disputed factual issues to yield to the state rule in the interest of uniformity of outcome. 
  • The Court stated that there was a strong federal policy against allowing state rules to disrupt the judge-jury relationship in the federal courts.

CONCLUSION
The Supreme Court reversed the judgment of the court of appeals that directed a verdict for respondent corporation in a negligence action. The Court also held that petitioner was entitled to a jury trial, even though under state law petitioner would not have received a jury trial. The Court stated that the federal policy favoring jury decisions of disputed fact questions should not yield to the state rule.

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