Dickins v. International Brotherhood of Teamsters, Chauffeurs, Warehousemen & Helpers

171 F.2d 21, 84 U.S. App. D.C. 51, 1948 U.S. App. LEXIS 2776
CourtCourt of Appeals for the D.C. Circuit
DecidedOctober 18, 1948
Docket9492
StatusPublished
Cited by28 cases

This text of 171 F.2d 21 (Dickins v. International Brotherhood of Teamsters, Chauffeurs, Warehousemen & Helpers) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dickins v. International Brotherhood of Teamsters, Chauffeurs, Warehousemen & Helpers, 171 F.2d 21, 84 U.S. App. D.C. 51, 1948 U.S. App. LEXIS 2776 (D.C. Cir. 1948).

Opinion

WILBUR K. MILLER, Circuit Judge.

This is an appeal by Randolph Dickins, Jr., the unsucesssful plaintiff in a libel suit against International Brotherhood of Teamsters, Chauffeurs, Warhousemen and Helpers, and its president, Daniel J. Tobin.

In the summer and fall of 1944 the appellant, then twenty-three years of age and a lieutenant in the United States Navy, was an ambulatory patient at the Bethesda Naval Hospital, under treatment for fatigue. Being free for the evening of September 23, 1944, and having discovered thkt an old friend, Lieutenant Commander Suddeth, was stationed in Washington, he communicated with Suddeth and about 8:00 p. m. called on him at his apartment. About 9:00 p. m. Dickins and Suddeth each drank one rum highball. Suddeth apologized, Dickins said, because his supply of rum was then exhausted. Shortly after 10:00 o’clock they decided to visit the Statler Hotel, where they understood a dance for naval officers was held each Saturday night. They arrived at the hotel probably between 10 :30 and 10 :45 and proceeded to the mezzanine floor where Dickins said they inquired as to the location of the dance.

On the same evening the Teamsters’ union held a banquet, at the Statler Hotel at which the President of the United States was the guest of honor and the principal speaker. His address was completed at 10:22 p. m. and a few minutes after that the crowd left the banquet room and entered upon the mezzanine floor. Dickins and Suddeth became involved almost immediately in a political argument with certain of the banquet guests, and soon after they were engaged in a fight with a number of those persons. An assistant manager of the hotel, who was summoned, directed that the Shore Patrol be called. A naval policeman responded quickly and took Dickins and his companion to the Shore Patrol headquarters. There each made a written statement as to the affray and between 2:00 and 3:00 o’clock on the morning of Sunday, September 24, when the Patrol officers had ascertained that neither the hotel nor the union desired to prefer charges against them, they were released. A Shore Patrol vehicle took Suddeth to his apartment and returned Dickins to the Bethesda hospital.

The incident was not mentioned in the newspapers until October 1, 1944, when the Washington Times-Herald carried a story describing it as a brawl in which labor *23 leaders attacked the appellant and his companion, another young naval officer. 1

On the following day, October 2, the appellant voluntarily held a press conference at which he gave to some thirty newsmen his version of the affair, which was to the same general effect as the article in the previous day’s Times-Herald. He claimed that he and Suddeth had been attacked by members of the Teamsters’ union. The interview was published in the Washington Evening Star on that day, and thereafter more than ten thousand articles in the pattern of the Star story appeared in newspapers throughout the country.

On October 5, 1944, a senatorial subcommittee began an inquiry for the purpose of determining whether a • formal investigation of the incident should be made by the full committee. Dickins’ attorney filed with the subcommittee his client’s affidavit, as well as an affidavit by Suddeth, both of which substantially reiterated the version of the brawl which Dickins had given to the reporters on October 2. The union filed with the subcommittee a number of counter-affidavits. Following this the subcommittee decided not to hold an investigation and did not release the affidavits for publication. Dickins’ attorney, however, gave to the press on October 18 the affidavits of Suddeth and Dickins and these statements received wide publicity.

There appeared in the November, 1944, issue of “The International Teamster,” official magazine of the Teamsters’ union, an article entitled “Here’s the True Statler Story!” which included seven affidavits of persons who had been present on the mezzanine floor of the hotel during the incident. The article and the affidavits accused the two naval officers of being drunk, of using abusive and unprintably foul language concerning the President of the United States, of making unprovoked assaults upon the banquet guests, and of forcibly stopping a woman passerby and demanding to know for whom she intended to vote for president. The magazine was sent to those on the regular mailing list, consisting of more than 400,000 teamsters and about 1,200 others, including all members of Congress, a number of colleges, libraries, newspapers and other periodicals. In addition, copies were received through the mail by two Washington reporters, one of whom said the magazine had not been sent to him before or since.

Early in November, 1944, Dickins instituted this suit in the District Court of the United States for the District of Columbia to recover $100,000 in actual damages and *24 $100,000 in punitive damages from the Teamsters’ union and Tobin because of the publication to which reference has just been made. The defendants, who are appellees here, pleaded truth and privilege.

When the author of a libel writes under the compulsion of a legal or moral duty, or for the protection of his own rights or interests, that which he writes is a privileged communication unless the writer be actuated by malice. 2 The appellant testified that, before the publication of which he here complains, he himself released to the press his own charges that members of the union assaulted him and his companion. His act in so doing cast upon the union the moral duty and consequently conferred upon it the legal right to publish a reply which, even if it were false, was privileged unless the plaintiff proved the defendant knew it to be false or otherwise proved actual malice in the publication.

The trial judge correctly instructed the jury to determine first whether the charges against Dickins contained in the publication were substantially true; if they were, then they need go no further but simply find for the defendants. On the other hand, he informed the jury, if they should find those charges false, they should then take up the question of conditional privilege and determine the presence or absence of actual malice. 3

After the jurors had been out several hours they sent to the presiding judge the following written communication:

“Your Honor: Is a person responsible for publications that grow out of a signed statement to the press ?
“(Signed) Jury”

Upon receipt of this question the judge called counsel to the bench and discussed the matter with them. He closed the colloquy by saying, “This is simply a question of law which I shall answer ‘Yes.’ I do not see anything else to it. I shall hand to the reporter, for her notes, a copy of their note and my answer.” No objection was made by counsel. The verdict of the jury was for the defendants and Dickins’ motion for a new trial was in due course overruled.

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Bluebook (online)
171 F.2d 21, 84 U.S. App. D.C. 51, 1948 U.S. App. LEXIS 2776, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dickins-v-international-brotherhood-of-teamsters-chauffeurs-warehousemen-cadc-1948.