Sampson, Administrator, General Services Administration, et al. v. Murray
415 U.S. 61 (1974)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A probationary federal employee seeking a preliminary injunction to prevent their discharge must make a showing of irreparable injury sufficient to overcome the government's wide latitude in managing its internal affairs. The temporary loss of income and damage to reputation that are a normal incident of a discharge are not sufficient to constitute irreparable injury, especially when a statutory remedy like the Back Pay Act is available.
Facts:
- Jeanne M. Murray was a probationary employee working as a program analyst for the Public Buildings Service of the General Services Administration (GSA).
- Approximately four months into her one-year probationary period, Murray received a written notice from Acting Commissioner W. H. Sanders that she would be discharged.
- The stated reason for her discharge was her 'complete unwillingness to follow office procedure and to accept direction from [her] supervisors.'
- Following the notice, Murray's counsel was shown an internal memorandum that formed the basis for the discharge decision.
- This memorandum discussed not only Murray's performance at GSA but also her conduct during previous employment at the Defense Intelligence Agency (DIA).
- Under Civil Service regulations, a dismissal based on conditions arising 'before appointment' entitles the employee to more extensive procedural protections than a dismissal for performance during probation.
- Murray's counsel requested these enhanced procedures, arguing that the inclusion of her DIA service as a basis for termination triggered the relevant regulation.
- The GSA denied Murray's request for the more elaborate procedural protections.
Procedural Posture:
- Murray filed an administrative appeal with the Civil Service Commission, alleging her termination was not effected in accordance with procedural requirements.
- While the administrative appeal was pending, Murray sued the government in the U.S. District Court for the District of Columbia, seeking to enjoin her dismissal.
- The District Court (trial court) granted a temporary restraining order (TRO).
- After a hearing where the government declined to produce a key witness, the District Court continued the TRO indefinitely, effectively making it a preliminary injunction.
- The government, as appellant, appealed the order to the U.S. Court of Appeals for the District of Columbia Circuit.
- A divided panel of the Court of Appeals (intermediate appellate court) affirmed the District Court's order, holding that the court had authority to grant the relief.
- The Supreme Court granted the government's petition for a writ of certiorari.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a probationary federal employee's claim of temporary loss of income and damage to reputation constitute a sufficient showing of irreparable injury to justify a federal district court's preliminary injunction preventing the employee's discharge pending administrative review?
Opinions:
Majority - Justice Rehnquist
No, a probationary federal employee's claim of temporary loss of income and damage to reputation does not constitute a sufficient showing of irreparable injury. While federal district courts are not wholly without authority to grant injunctive relief in such cases, the employee must demonstrate irreparable injury of a kind and degree sufficient to override the strong governmental interests in managing its internal affairs and the established administrative process. The temporary loss of income, compensable under the Back Pay Act, is not irreparable. Similarly, any reputational harm from procedural irregularities can be cured through the administrative review process. The Court reasoned that Congress established a comprehensive scheme for federal employment disputes, intending for administrative appeals and the Back Pay Act to be the primary remedies, thereby limiting the role of preliminary injunctive relief to only the most extraordinary of circumstances.
Dissenting - Justice Douglas
Yes, a probationary federal employee's claim could constitute a sufficient showing of irreparable injury, and the District Court acted properly to preserve the status quo. The District Court's stay supplemented, rather than interfered with, the administrative process, as the Civil Service Commission lacks the power to issue such stays. The majority incorrectly frames the issue; the lower court was merely attempting to hold a hearing on irreparable injury, which the government blocked. Being discharged from federal employment can inflict a lasting stigma that harms future employability, an injury that back pay cannot fully remedy. The court should have allowed the employee the chance to prove this irreparable harm.
Dissenting - Justice Marshall
The issue should not be decided, as the lower court's order was a non-appealable temporary restraining order (TRO), not a preliminary injunction. By extending the TRO indefinitely without making findings of fact and conclusions of law as required by Federal Rule of Civil Procedure 52(a), the District Court issued an invalid order. The proper course is to remand, not for the Supreme Court to rule on the merits. Furthermore, the majority wrongly creates a heightened standard for irreparable injury. For many people without savings, a loss of income is truly irreparable, potentially leading to eviction or inability to afford necessities, and back pay years later is an inadequate remedy for this immediate harm. The majority also misunderstands the reputational injury, which stems from the inability to correct a false record before the damage of dismissal is done.
Analysis:
This case significantly raises the bar for federal employees, particularly probationary ones, seeking preliminary injunctions to block their dismissal. By holding that temporary loss of income and reputational harm are generally not 'irreparable,' the Court effectively channels these disputes into the administrative process, with back pay as the primary remedy. This decision reinforces judicial deference to the executive branch's internal personnel management and makes it much more difficult for discharged employees to maintain the status quo while their claims are adjudicated. It requires a plaintiff to show 'genuinely extraordinary' circumstances, a high and difficult-to-define standard, for a court to intervene before the administrative process is complete.
