Award No. 1
r case No. 1



PARTIES TO DISPUTE: United Transportation Union



                    Norfolk and Western Roitway Company


STAfTV4fi`:T OF CLAIM: Appnul of Brakeman T. E. Finnerty for reinstatement
with full :;eni')rity uni:a;t._li.r_'d, removal of discip
linr, from the record, full. pay fur all time Lu:_t, rer:ovQry for tha loss
or' all fringe benefits (current gull future), including (.Plc monetary
value thereof in the cane of benefits <i::em:d ir:'ol)lacc:r.bLe, and 1?uhl.'.c
written apology to Mr. Finnerty from both the Norfolk and Western R:nii
way Company as an employer arid from Trainnla::!:·?r .J. C:. Smith personally
and a;; a representative o.f t!TU Norfolk anU l,r r:a-·;:rn Railway Cum(>;ar:y fmr
'iuf&:nation of character and thr: rlrivc?r·r,.r el'K.:t; it has had on hi.:. :;t.,,:rd
ind in the community, his ability to obtain ':!.: arw.:; and ':!mt' oymf'rtt And
the general defamatory nature of th, action.

.. ;'rATE24EPd'1' OF FACTS: The facts in r,hT, cu; ", r.:L a. 1.^!cxl', . r. :tl, aT·'
uh:_rt .r.'r.,:i;C:R;Ia L. ·J. :ir:~tr, o(.;y.rt:n: :y :11ltlu:rsal .. MnF'.
°'.rt of as on-duty in;ury. The Carrier's &:;.;n Agent, Mr.·javr.y.;", 1. ,al
w.xtlr.d upon him, whether ty· ::.lrpoinL.lmnt or n.:!; i:. not um,ireLy cl;)a:·,
u!n: %as attempting to iJr.^31T6.~'. il ..'^.t;f.l.t'.?11:11(,.

Thc: Ci;:fnlant at tile tin! was an en,nl r!yuw of the Carrier, but off duty Im:t:n,rr,e of an injury not railroad connected, since December .',, lcJ7t,. Mr. Finnerty also oc':ur.'.od I;:.f. office of Vice General Chairman, Genera.). Cunmrittee of Adjustment, h':y;islative Representative--10>6; and had boon dosignated of record .s .',:; legal counsel by the G'cm:ral Committee ('fr. pagea 1-19 and 3;). . ., . Board presumes his position ar, outlined Above was tllu reas·:n:r th .t ..._ injured employee, L. J. Scott, aI)proacla`d hir,. Finnerty for advic .

Claim Agent Savage had visited the !Tome of the n,jured employee, Brakeman :icon, on February :?3, L977 _. Which time the iny_Ireci employee Scott in?'c)rnlt,d him he was belly,; r ^re w ;:ted by Claimant; and again fn May, 1977,. !,') ask for a repra:st.nl:,a· ::: _ %ter which, according to such request, w:::: furnished him.

                    This took p1uC:: after

                          r l.:, Ln,jurerl Iflplr,yn,: lnd

til:W'.rl tn: t!:·? General _l'.i>(.'lun ;1bOi;! l:I ..L(,o;i,ll n;l
! ha.l a^,k·^_rl him acl'ri ca .. I) the n!atc':r. 'fil. ,c:rn:,r;zl t;;o;i t:ou:r f.iT..'.v . ._
, =l,:.i thuL till' L'yil?r'nnl 'f:,rl.?J"r), l;I'.v.·i·'1!1 ,'t`t)I,t, /'l:!. L:. :'.n;fa. S'll ,
.. . .u: .:u·'rty, Lit.. 1r: z" lar'.I I""!..l:n .111r1 (~:l~:l·1. ' ·t ;,. :l ~ W I' '.ll .n :'1
                                                        1 r .1!: r

_ nua'.ndcd U'I'U c:l:l;::a.l.
No 1 - pa--e

2

                  it is the position of Lllo t)r!,anization than th--~ r·eprr:::entation .letter furnished by the injured


~,;-.ioy~e at tire requ~-'.t of Claim Agont ~avrz~;.; wn:> for the purlTO;:·: of
:n:-:1ating the injured employee from furthhr direct visits. said
-~:scirtation letter which is reproduc-od be low seems to be the sub-
::~ti;e cause of Claimant's di-charge:

LAW OFFICES

t,~ELANEY & PERKINS& FINNERTY
;C~?3 SOUTH BRADDOCK AVENUE
PITTSBURGH, PA. 15218 · (412) 241-8130

IN REFERENCE TO:

AIRMAIL Q FIRST CLASS MAR O INTER OFrI[E Q

ToR hORF013f & WESTERN RWY. CO.
Claims Department
J. J. Ryland, District Claims Agent
BRF4STER, OHIO

HOW TO USE THIS

        lC1TER TO SAVE TIME.


TYW .Y vrife rout real, in 1h, "." Th., ..J
Ih. .h,N mpE to m and 4..P the Pint ca,/ Mr Your inlet.
Vav'll re Am, and -0 11 hqv. an'",

murh Iftwl Thank Va..
7-77

DATE..---- ___. ._.Sauo

- 1161 G : ';U4

Dear Sir: GATE-Nay-5, 1'77

F':.ease be advised that I represent L.J. scot

brakeman - Rook, Pa., IN RE: personal injur;.Il and lost wages due to incident occurring at kc:ok Yard on December" 10

z:.ndly address-any--further ouestions- with rr.gard to this-incident to me at the addrrssj above,

Very truly yours,

                                Pc.S a i g-1

                                Case No. 1. - page 3


            "Dr-Qwstcr, Ohio

            June 17, 19'7


CERTIFIED MAIL
RETURN RECEIPT REQUESTED

Mr. Timothy E. Finnerty
129 Barnes Street
Pittsburgh, Pennsylvania ).52:'1

Mr. Timothy E. Finnerty:

You are hereby notified 4o report. to the office of the kosistant Superintendent at Rook, Penn,-,ylvania, at 9:GG A.I:I., Friday, June 24, 1977, for a formal trial to determine the facts and your responsibility in connection with your unfaith-fulness and disloyalty to the Norfolk and Wes-tcrn Railwa;, Company by representing Brak--:man L. J. Scott., an empLoyc, of this Carrier, as legal counsel in progression of a perco:al injury claim for reason of' 'per.,k~ilal. injuries and lo:~t w.~ges due to incident occurring at Pool. Yard on 1)e:cmL~cr 1(), 1');b.'

"If you desire to have a repro. son;;;,tive and/or witnesses at the formal trial, please: arrango for their presence.

                                Sincerely,


                                J. G. Smith

                                Trairunaster


Following witnesses arrange to ho present:

Messrs. R. L. Musick
' J. J. Ryland
          J. R. Savage


Other witnesses may be called."

          Sub-e(luent to inveSti;',.it.I,t)I1, the Carrier wrote the Claimant as follow.::

p(6 at ~~f

CJ,,e Nu. 1 - t~c:,,e 4

        "Brewster, Ohio, July 15, 1977


        Mr. Timothy E. Finnerty 329 Barnes Street Pittsburgh, Fennsylvani a 15:'..2.1


        Dear Sir:


        Reference is made to the normal triaL held in the Office of the Assistant Superintendent at Rook, Pennsylvania at 9:00 A.M., July 6, 1977, to determine tho facts and your responsibility in connection with your unfaithfulness and disloyalty to the Norfolk and Western Railway Company by representing Blakeman L. J. Scott, an employee of this Carrier, as legal counsel in progression of a personal. injury claim for rca:i"n of 'personal injuries and Lost war;on due to incident occurring at Rook Yard on Ducomber 10, 1 0 76. '


        Fur your respunoihility a; dvvdlorod in the formal tr i"L, you are hereby assevood discipline ..., fuiLows:


                          ' DIVI SSAL'


        Please arrange to return all company property, in<: Lud i n; switch key, 1an_:orn, &o;: of Rule:., rte.


                                Your:; i.:'!tly,


                                J. U. Smith

        . Trainmanter


_ITNDINC;: The Board ha:, searched the entire record of th i
case with great care. The Carrier has the bur,.n f proof to support its formal charge "to determine the facts and y. :r ._~ponsibility in connection with your unfaithfulness and disloyalt; to on" Norfolk and Western, . . .."

                  Mlle Carrier states 7.R Lh.:i submission, page r:

"In Kew of C1limanL'n own tO:timony glvca at n trial, it is apparont Claimant reprn:~nrwd Brakeman WccLt an le. il t o"Asul in the progrwsjt.n of paracnal injury : UL, otc."
                                        Pea P-(SH


                                        Case No. 1 - page 5


                  However, commencing .at Page 3$ of the transcript, testimony of Claimant, i:; ao follows:


          Q. Have you ever talked to Mr. Savage or any other

                  agent for the Norfolk and Western regarding the

                  claim of Mr. Scott? ,


          A. I have had no personil contact other than the

                  lottor that I sent with :-i.th^r Mr. Savago or

                  Mr. Hyland.


          Q. liavc you filed :ct:i.t o;l b,A1aLf of Mr. Scott, in

                  the Court of LhL~ Unit,,!(! ..'t.,xt.e:`.'


          A. No I have not.


                  As a union representative, do you have the right; to represent Mr. 2cott, whether or not you are an attorney?


          A. It i.^, my understanctying oC the law that it is my

                  right to so represent Mr. Scott, both as an

                  officer of the court art as an officer of this

                  union.


          Q. And in representing Mr. Scott, did you have any

                  intentions of being disloyal or unfaithful to the

                  Norfolk and Western Railway Company?


          A. None whatsoever. The -nly alternative I had i:

                  representing Mr. Scott, was to say that, ono, a

                  he had contacted me rolahLvo to the visits of :e

                  railway claim agents and knowing that once an

                  attorney had been att.ai neat, they would no long..

                  talk to him, it being Mr. Scott's wish that he :eve

                  no further contact with the railway claim agen; .-, as

                  their visits, had been unannounced and upset h:. .

                  Hi: contacted me and ashod me if I would get in ,ouch

                  with the.-., which I did with letter, the one in ·oduced

                  as evidence hero.


                  This cvidence does not sQom to have been rebut d in th: re·cord. There i s L'urther evidence: i n t

_ - rd That tt:C Claim heli'IrtmL:tli· has novor contacted Mr'. 1''i nlwrty :i a
    :·e:-:utat_vc: for Mr. Scott on his pcrson:Ll injury claim. 'L'r., p::, 1,.0.

,. ... _.; evidence that, lil.` CJeeimint was n,w-r rr"O&Icd ho w.uiA nev .e .,.,·?tt.~d t", handle' x·:IL~r·'I~ e:l.;el:rl:' 'as an Itl.ornoy.
QLr3 a 18`A
(%asu No. I - page 6

There .: no ovidertco Claiv:anc ever enterod into an attorney and cl icnt cintract or fat; arranf;emant r that there was an appearance in court. ,:r even conferences. The Claimant bases his ri,,:At to coun3el urahernn Scott., which i : all the record shows he actually did do, acnordl;: Lo his union job :anti re..ponribi.lity. He ralicd for his juotiiic oian upon UTU v:, VirZinia, -77 US 1 which in a reazonably similar ea.aQ, the Supreme Court said:

        "It cannot he aerit u·wLy doubted that the First Amendment's guarantees of :'roe speech, petition and assembly give railroad workor& the right to gather together for the lawful purpoon ,%f helping arid advisin ()n2 another in asserting the rrKnts Congress gale them in the Safety Appliance Act and On Federal Foployers' Liability act, statutory right.,, wll ice would be rain and futile if the workers could not, talk together freely as

        . to the best cr>uroo to follow. The right of members t·: consult with each other in a frot-rnal orpanizataon necessarily includos tht. right t,tr nelect a epokesmnn from their ntrmhtr who could lr· oxipoctod to give tht: wisest counoei. That. i.: tea rolq played by the mem6er:; who carry out the P,·al .lid frtrpriw. And tilt.: KOK of the worker: per^onally or thooo,;:t a special dopartmont of their Brutuorhood to advice concerning the need Wr legal assistance -- anti, most inp,rtantly, what lawyer a member cuula conVidontiy raly . n -- 15 an inseparable part of this, .^t n:ll.tt~lt.i:,n:.il.ly ru trantoud right to assist. surd advise ea,:a ut.h.,r."


This s·~t~m,; to cover :tlronrt any action:; thra tl, 1'000rd ::bows lrnd bt:on orr',ag, d ill by lair. Front ty 11 t<., the time of the i Rvos', L ;uWi "n. TIwc-, i s no OR)wl rig that t,l n> : r:: l,t:cn arty dotrirnent t.ta the C;irrier.

                  Tilt: Board io trot conv;nt:vd that thin Carrier en:;tailled .i l,^ border: ·1. r61·uo1' that Mr. Finnor y repre:;cllteti Mr. Scott i n a legal action again. 1; the Carri or.


'A:lARD: Clsim auctOnud in W h Claimant Finnarty is
reinstated to his pr'uvious position with full
seniority unimpaired and removal of.' said discipline from his reco.d,
together with pay for time lost from Au,nnnt 1, 1977, which the
r acnrd shows was the date he was able to r-turn to work from .sick
1 .._,vr,. The Board ii r:r rr,l allt.llttri ty to t·tl i rrl..t apolor-i t,;;, :trill ccrt . i 11
hhnr exuranuou ; mctLWr.' rrwirLi,rnt"l in I,It·' ,Q:rirn.
pLaiBLl

Case No. 1 - page

                  Carrier is ordered to make this award effective within thirty days.


                  ~·v~ret

                      &~z J-4

                      7i-~, Cliurman and Neutral


                      w


                                                I

. . the employees ~~ Fir t

                                4-F

                                    . i.· Uarr3cr


C 1 , :eland, Ohio