## Facts

- Jeanne M. Murray was a probationary employee of the General Services Administration (GSA) who received notice that she would be discharged on a specified date.
- Murray alleged the agency failed to follow Civil Service regulations governing discharge of probationary employees.
- She sought temporary injunctive relief to prevent her dismissal while she pursued administrative review before the Civil Service Commission (CSC).
- The district court issued a temporary restraining order and, after an adversary hearing, continued interim relief that effectively required the Government to keep Murray employed pending the administrative process.
- The Government declined to present the discharging official to testify as to the reasons for discharge, arguing the court lacked authority to probe the merits or to order continued employment at that stage.
- The D.C. Circuit affirmed, holding the interim relief was within the district court’s discretion.

## Issues

1. Whether, and to what extent, a federal district court may grant interim injunctive relief that effectively maintains a discharged probationary federal employee in her position before completion of the CSC process.
2. Whether the employee showed the kind and degree of irreparable injury required to justify such extraordinary preliminary relief against the federal Government.

## Decision

- The Supreme Court reversed.
- The Court held that a district court is not categorically barred from granting interim injunctive relief in federal employee discharge disputes.
- The Court concluded, however, that the interim order here could not be sustained under governing equitable standards.
- The Court emphasized that judicial involvement is generally premature before final administrative action establishes whether the discharge failed to conform to applicable regulations.
- The Court held the injunction’s mandatory character (compelling continued employment) and its disruptive effect on federal personnel administration weighed strongly against relief absent a compelling showing of irreparable harm.
- The Court found Murray’s asserted harms, including temporary loss of income and alleged reputational injury, insufficient to meet the heightened irreparable-injury requirement in this context.

## Legal Principles

- Interim equitable relief interfering with federal personnel decisions is disfavored; courts generally await final administrative action before assessing regulatory compliance.
- In discharge disputes involving federal employees, especially where the requested order effectively mandates continued employment, the plaintiff must show irreparable injury sufficient in kind and degree to override deference to governmental administration of internal affairs.
- Temporary loss of income recoverable through later remedies ordinarily does not constitute irreparable injury.
- Equity’s traditional reluctance to enforce personal service relationships by mandatory injunction counsels against ordering continued employment absent extraordinary circumstances.
- Preliminary relief that alters, rather than preserves, the status quo (mandatory reinstatement in substance) requires especially strong justification.

## Conclusion

The Court dissolved interim relief that effectively kept a probationary federal employee in her job during pending administrative review, holding that such mandatory interference with federal personnel administration requires a stringent showing of irreparable injury not satisfied by ordinary economic loss or generalized reputational harm.


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