Civil Procedure Keyed to Friedenthal
Byrd v. Blue Ridge Rural Electric Cooperative, Inc.
CaseCast™ – "What you need to know"
Byrd (Plaintiff), a resident of North Carolina, sued Blue Ridge Rural Electric Cooperative, Inc. (Defendant), a South Carolina corporation, for negligence in federal court in South Carolina. Plaintiff was injured while working for a construction contractor that had a subcontract with Defendant. Defendant asserted an affirmative defense that Plaintiff was barred from suit under the South Carolina Workmen’s Compensation Act because Plaintiff was a “statutory employee” and must accept statutory compensation as his exclusive remedy. The jury returned a verdict for Plaintiff. The Court of Appeals reversed and directed judgment for Defendant, holding that Plaintiff was in fact a statutory employee. Plaintiff appealed, arguing that the Court of Appeals should have remanded to give Plaintiff an opportunity to introduce further evidence. On appeal, the United States Supreme Court held in favor of Plaintiff and addressed an additional question of whether there should be a bench trial (as would be the case under South Carolina law) or a jury trial (as required in federal court by the 7th Amendment).
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