U.S. Federal Civil Procedure

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Byrd v. Blue Ridge Rural Electric Cooperative (1958)

The likelihood of a different result is not so strong as to require the federal court practice of jury determination of disputed factual issues to yield to the state rule in the interest of uniformity of outcome.

This Court in Erie R. Co. v. Tompkins, held that federal courts in diversity suits need to respect the definition of state-created rights and obligations of state courts. Therefore, the Court in this case examined the decision in Adams v. Davison-Paxon Co., to determine whether “it is bound up with these rights and obligations in such a way that its application in the federal court is required.”
The rule in South Carolina reflects a policy of allowing the jury to decide all factual issues, except the affirmative defense of immunity. Therefore, the Court concluded that this requirement was merely procedural and was not intended to be “bound up with the definition of the rights and obligations of the parties.”

The cases following the decision in Erie state that federal courts should conform to state rules even if it is only a procedural rule, when the application of state rules as opposed to federal rules would substantially alter the outcome of the litigation. However, the Court in Herron v. South Pacific Co., 283 U.S. 91 (1931), stated that the application of state rules may not “alter the essential character or function of the federal court.”

The Seventh Amendment protection of the right to a jury trial and the prescribed function of the jury is a fundamental right, which should not be governed by state law in federal court.

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