Byrd v. Blue Ridge Rural Electric Cooperative, Inc.

Facts

Byrd was employed as a lineman by R.H. Bouligny, Inc., a construction contractor that had a $334,300 contract with Blue Ridge Electric Cooperative to build new power lines, reconvert existing lines, and construct substations. While connecting power lines to one of the new substations, Byrd was injured. He filed a workers’ compensation claim against his employer and received benefits. He then filed a diversity action against Blue Ridge in federal court, alleging negligence. Blue Ridge defended by claiming that under South Carolina’s Workmen’s Compensation Act, Byrd was its “statutory employee” because the work contracted to Byrd’s employer was part of Blue Ridge’s “trade, business or occupation.” If true, this would bar Byrd’s negligence action, as workers’ compensation would be his exclusive remedy. The district judge rejected this defense, ruling that Blue Ridge could only be a statutory employer if it performed construction work for others, not just for itself. The jury returned a verdict for Byrd. The Court of Appeals reversed, finding that the district court misinterpreted South Carolina law and that the evidence established Blue Ridge was in the business of constructing lines and substations necessary for its power distribution.