[Leon]

Here is an example of the Lenox brown next to a Lenox black. The brown is larger to try to accentuate the difference. The Brown one (not mine) is a Lajoie w/bat and I think the black one is Chase w/trophy...Sorry for the poor scan but you can still see the shade difference.

As for the original question, I would think that PSA should put "brown" on the label but don't know their stance nor do I remember seeing one in their holder (I am sure there are some, labeled correctly or not).