Browne v. International Brotherhood of Teamsters, Local Union 851
Plaintiff Thomas Browne, a security guard, sought to recover for personal injuries after being struck by a brick thrown during a union picket line. The incident occurred while he was escorting a truck through a picket line authorized and directed by defendant International Brotherhood of Teamsters, Local Union 851, at Emery's facility. The jury found in favor of the plaintiff, awarding $400,000 plus interest and costs, based on evidence that the union was aware of recurring violence and failed to address it. The Supreme Court, Appellate Division, affirmed the judgment, rejecting the union's arguments that Labor Law § 807 (6) applied to damage claims and that the security log was improperly admitted. The court emphasized that specific proof of 'knowing tolerance' by other union officials was not required, as the shop steward on the scene was clothed with plenary authority to direct the strike on behalf of the union.