United States v. Local 807 of International Brotherhood of Teamsters, Chauffeurs, Stablemen & Helpers

Background

The Government prosecuted Local 807, a New York truck drivers’ union local, and 26 members for conspiring to use threats and violence to extract payments from out-of-state truck owners and drivers entering the city. The payments were the union day rates ($9.42 for large trucks, $8.41 for small). In some incidents the union members drove and unloaded the trucks; in others they demanded money and left or offered services that were refused. A jury convicted; the appeals court reversed, and the Supreme Court agreed to decide how broadly the Anti‑Racketeering Act’s exception for "the payment of wages by a bona‑fide employer to a bona‑fide employee" applies.

Reasoning

The core legal question was whether the statutory wage exception covers (a) outsiders seeking jobs, (b) payments made to buy "protection" rather than service, or (c) payments made after an employer rejected a sincere offer of work. Relying on legislative history and the statute’s language, the Court held the exception is not limited to prior employees, that the defendants’ purpose controls (not the owners’ motive), and that a genuine plan to obtain wages can fall within the exception even if employers reject services. The Court found the trial judge’s instructions wrongly made guilt depend on the owners’ motive, so the convictions could not stand.

Real world impact

The decision narrows the scope of federal anti‑racketeering prosecutions against ordinary union tactics and requires juries to focus on the union members’ intent. It also makes clear violent acts remain subject to ordinary state and local criminal laws. The ruling reversed these convictions and requires clearer jury instructions in similar cases.

Dissents or concurrances

Chief Justice Stone dissented, arguing the convictions should be affirmed because payments made to avoid violence are not wages and the jury was entitled to consider the owners’ motives.