Byrd v. Blue Ridge Rural Electric Cooperative

356 U.S. 525, 78 S. Ct. 893 (1958)

 

RULE:

Even if a jury determination of an issue may substantially affect the outcome of a case, the "Outcome Determinative" test set forth in Guaranty Trust Co. v. York does not automatically prevail. The court must look at the "Outcome Determinative" test and any countervailing federal policies.

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, but the case was brought to federal court under diversity jurisdiction as petitioner was a North Carolina residence and the respondent was a South Carolina Company. Responded Blue Ridge argued that the case should be heard under South Carolina state law which held that the employment issues in this case should be decided by a judge, not a jury. Petitioner Byrd argued that under federal law his Seventh Amendment right to a jury trial should trump state law. The trial court agreed with petitioner and the court of appeals reversed, finding for Blue Ridge. The Supreme Court granted cert.

ISSUE:

Is one still entitled to jury trial before a federal court even if state law prohibits it?

ANSWER:

Yes.

CONCLUSION:

The Court stated that the federal policy favoring jury decisions of disputed fact questions should not yield to the state rule. The Court has a vested interest in preserving the the judge-jury relationship in the federal courts. This Court sustained the action of the trial judge, holding that "state laws cannot alter the essential character or function of a federal court" because that function "is not in any sense a local matter, and state statutes which would interfere with the appropriate performance of that function are not binding upon the federal court under either the Conformity Act or the 'rules of decision' Act." Perhaps even more clearly in light of the influence of the Seventh Amendment, the function assigned to the jury is an essential factor in the process for which the Federal Constitution provides.

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