Conflicts Keyed to Currie
Byrd v. Blue Ridge Rural Electric Cooperative, Inc.
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Byrd (Plaintiff) was an employee of a subcontractor to Blue Ridge Rural Electric Coop., Inc. (Blue Ridge) (Defendant) and was injured on the job in South Carolina. South Carolina provided a workman’s compensation system for statutorily defined employees. Plaintiff brought suit against Defendant in federal district court in South Carolina on the grounds of diversity jurisdiction. Defendant asserted a defense that, since Plaintiff was a statutory employee of the subcontractor, his exclusive remedy was in workman’s compensation. Defendant argued further that the issue of whether Plaintiff was a statutory employee was to be decided by the judge, not a jury, since the Supreme Court of South Carolina had held that this issue of fact was for the judge to decide rather than a jury. The trial court submitted the factual determination of the defense to a jury that found in favor of Byrd (Plaintiff). Blue Ridge (Defendant) appealed.
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