Byrd v. Blue Ridge Rural Electric Cooperative
United States Supreme Court
356 U.S. 525 (1958)
Byrd (plaintiff) was employed as an independent contractor by Blue Ridge Rural Electric Cooperative (Blue Ridge) (defendant) and was injured on the job. Byrd sued for negligence. Blue Ridge argued that because Byrd was doing the same work as its regular employees, Byrd was a statutory employee as defined by the South Carolina Workmen's Compensation Act (SCWCA). SCWCA does not allow employees to sue. Instead, employees must accept the statutory compensation benefits. The issue of whether Byrd qualifies as a "statutory employee" must be decided by the trier of fact. The state practice would have the factual question decided by the judge. However, the federal practice is to leave such a question up to the jury. The trial court found that following the state practice was appropriate. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Brennan, J.)