Byrd v. Blue Ridge Rural Elec. Coop.

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Facts: Byrd was an employee of R.H. Bouligny, who held a contract with Defendant to install and upgrade power lines and construct two substations and a breaker station. Byrd was injured while installing power lines to a new substation. Byrd qualified as a statutory employee under South Carolina Workmen's Compensation Act--he was a statutory employee of Blue Ridge because he was doing the type of work that Blue Ridge usually does. In state practice, the judge always decides if he was a statutory employee. In federal practice, a jury decides if he is a statutory employee.

Procedural History: Case was brought in the District County for the Western District of South Carolina, based on diversity jurisdiction. Plaintiff sued for damages for injuries allegedly caused by the defendant's negligence. District Ct. gave judgment to Plaintiff on a jury verdict. Court of Appeals reversed.

Issues:

  1. Whether the ct of Appeals erred in directing judgment for the defendant without remand to give plaintiff an opportunity to introduce more evidence, and
  2. whether the plaintiff is entitled to a jury determination of the factual issues raised by this defense.

Holding: Byrd is entitled to a jury, following federal law.

Reasons: three part analysis for what law should be applied:

  1. Integral part of the state statute.
  2. Importance of the federal interest.
  3. Outcome determinativeness.

Judgment: Reversed.