In Browne v. International Bhd. of Teamsters (203 A.D.2d 13 [1st Dept 1994]), which involved an assault against a security guard by a union member during a strike, the Court upheld a jury charge that in order "to place responsibility on the union," the plaintiff must prove "that the union was aware [on the date of the assault] that violence or threats of violence had become an every day occurrence in the strike and that the union either openly encouraged such violence and threats or deliberately failed to check it or give orders countermanding it." (Id. at 14.) Browne held that the stricter Labor Law 807 standard for imposing liability on a union for the acts of its members, which requires proof of the union's authorization or ratification of such acts, applies only to injunctions issued in labor disputes, and not to damage claims against the union. (Id. at 14-15.)