The Limits of State Power in Federal Courts

Case: Byrd v. Blue Ridge Rural Electric Cooperative

Parties: Plaintiff - Byrd

Defendant - Blue Ridge

Procedural History/Facts: Petitioner sued respondent for negligence (tort), in

the Federal District Court because of diversity. Respondent contended that
petitioner was respondent's employee for purposes of the State Workmen's
Compensation Act and that the Act provided petitioner's exclusive remedy. Trial
Judge then decided, (after hearing defendant's dubious testimony), that the facts
are irrelevant and need not go to a jury because of the trial judge's
interpretation of the state statute.

Issue: Whether the plaintiff is covered by the South Carolina Workmen's

Compensation Act and therefore is barred from any other remedy against his
employer.

Holding: Reversed and remanded.

Reasoning: The Court, in a majority opinion by Justice William Brennan, first

discussed whether question issue should be decided by a jury or by a court. The
court notes that while in South Carolina the court decided the question, no reason
is given for why the jury is allowed to decide all other factual issues except
whether the plaintiff was covered by the South Carolina Workmen's compensation
act. The courts say that this requirement is a "form and mode" of enforcing the
defendant's immunity from prosecution and not a rule.

The court then discuss the outcome determinative test discussed first Guaranty
Trust Co. v. York. The court says that if reaching the same outcome were the only
consideration then the federal court would have to follow state practice. However,
in this case, following the state practice would disrupt the federal system of
allocating functions between judges and juries. The state law should not be
allowed to interfere with this judge-jury relationship especially considering the
Seventh Amendment to the United States Constitution.

Thus the court found that the possibility of a different outcome was less
important than preserving the judge-jury function allocations in the federal
system.

Notes

• Will you get a jury in a workers comp case?

○ State would not give you, but fed would give you
○ Is the issue substantive or procedural?
§ It was procedural -
□ State didn’t state a reason (236 - look at strength of fed
reason)
® FED REASON STRONGER/better - They decided having jury
better then not having jury (re-creating swift)
□7th amendment doesn’t apply to the states (right to jury)