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Keywords

lawsuittortplaintiffdamagesinjunctiontrialclass actionlegislative intent

plaintiffdamagespleaclass action

Related Cases

Burns Jackson Miller Summit & Spitzer v. Lindner, 59 N.Y.2d 314, 451 N.E.2d 459, 464 N.Y.S.2d 712, 115 L.R.R.M. (BNA) 3454

Facts

The case arose from a mass transit strike in April 1980, which led two law firms, Burns Jackson and Jackson, Lewis, to file separate lawsuits against the Transport Workers Union and the Amalgamated Transit Union. Burns Jackson's class action sought $50 million per day in damages, alleging violations of the Civil Service Law and a preliminary injunction. Jackson, Lewis's action sought $25,000 in damages for various claims, including violation of the Taylor Law and intentional interference with business. Both actions were joined for trial, and the unions moved to dismiss for failure to state a cause of action.

The first, begun in Queens County by Burns Jackson Miller Summit & Spitzer (“Burns Jackson”), is a class action against the Transport Workers Union of America, AFL–CIO (TWU), the Amalgamated Transit Union, AFL–CIO (ATU), Local 100 of TWU, Locals 726 and 1056 of ATU and their respective officers.

Issue

The main legal issues were whether the plaintiffs could maintain a private cause of action under the Taylor Law and whether their claims for prima facie tort, public nuisance, and intentional interference with business were valid.

The Taylor Law proscription against strikes by public employees neither preempts the right of persons injured by an unlawful strike to sue for damages nor provides a private right to sue for violation of its provisions.

Rule

The court ruled that the Taylor Law does not provide a private cause of action for damages resulting from an illegal strike by public employees, and that common-law causes of action must be sufficiently stated to be recognized.

The causes of action pleaded by plaintiffs are, however, either not recognized under New York law or as pleaded do not sufficiently state a cause of action.

Analysis

The court analyzed the Taylor Law's provisions and legislative intent, concluding that it was not intended to preempt common-law remedies. However, the plaintiffs' claims were found to be insufficiently stated, as they did not meet the necessary legal standards for prima facie tort or public nuisance, and the alleged damages were deemed too general and common to the public to support a private action.

The effect of the Taylor Law, whether as preemptive of previously permissible private damage actions or as initiating a new form of private action for damages resulting from a strike in violation of its provisions, turns on what the Legislature intended.

Conclusion

The court affirmed the Appellate Division's dismissal of all causes of action, concluding that the plaintiffs failed to state valid claims under New York law.

We, therefore, affirm.

Who won?

The prevailing party was the Transport Workers Union and the Amalgamated Transit Union, as the court dismissed all claims brought by the law firms.

The order of the Appellate Division, 88 A.D.2d 50, 452 N.Y.S.2d 80, should, therefore, be affirmed, with costs.

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