Sampson v. Murray, 415 U.S. 61 (1974)

Sampson v. Murray

No. 72-403

Argued November 14, 1973
Decided February 19, 1974
415 U.S. 61

CERTIORARI TO THE UNITED STATES COURT OF APPEALS

FOR THE DISTRICT OF COLUMBIA CIRCUIT

Upon being notified that she was going to be discharged on a specific date from her position as a probationary Government employee, respondent filed this action claiming that the applicable Civil Service regulations for discharge of probationary employees had not been followed, and seeking a temporary injunction against her dismissal pending an administrative appeal to the Civil Service Commission (CSC). The District Court granted a temporary restraining order, and, after an adversary hearing at which the Government declined to produce the discharging official as a witness to testify as to the reasons for the dismissal, ordered the temporary injunctive relief continued. The Court of Appeals affirmed, rejecting the Government’s contention that the District Court had no authority to grant temporary injunctive relief in this class of cases, and holding that the relief granted was within the permissible bounds of the District Court’s discretion.

Held: While the District Court is not totally without authority to grant interim injunctive relief to a discharged Government employee, nevertheless under the standards that must govern the issuance of such relief, the District Court’s issuance of the temporary injunctive relief here cannot be sustained. Pp. 68-92.

(a) The District Court’s authority to review agency action, Service v. Dulles, 354 U.S. 363, does not come into play until it may be authoritatively said that the administrative decision to discharge an employee does, in fact, fail to conform to the applicable regulations, and until administrative action has become final, no court is in a position to say that such action did or did not conform to the regulations. Here, the District Court authorized, on an interim basis, relief that the CSC had neither considered nor authorized -- the mandatory reinstatement of respondent in her Government position. Scripps-Howard Radio v. FCC, 316 U.S. 4; FTC v. Dean Foods Co., 384 U.S. 597, distinguished. Pp. 71-78.

(b) Considering the disruptive effect that the grant of temporary relief here was likely to have on the administrative process, and in view of the historical denial of all equitable relief by federal courts in disputes involving discharge of Government employees, the well established rule that the Government be granted the widest latitude in handling it own internal affairs, and the traditional unwillingness of equity courts to enforce personal service contracts, the Court of Appeals erred in routinely applying the traditional standards governing more orthodox "stays," and respondent, at the very least, must show irreparable injury sufficient in kind and degree to override the foregoing factors. Pp. 78-84.

(c) Viewing the order at issue as a preliminary injunction, the Court of Appeals erred in suggesting that, at this stage of the proceeding, the District Court need not have concluded that there was actually irreparable injury, and in intimating that, as alleged in respondent’s unverified complaint, either loss of earning or damage to reputation might afford a basis for a finding of irreparable injury. Pp. 84-92.

149 U.S.App.D.C. 256, 462 F.2d 871, reversed.

REHNQUIST, J., delivered the opinion of the Court, in which BURGER, C.J., and STEWART, WHITE, BLACKMUN, and POWELL, JJ., joined. DOUGLAS, J., filed a dissenting opinion, post, p. 92. MARSHALL, J., filed a dissenting opinion, in which BRENNAN, J., joined, post, p. 97.