Sampson v. Murray - 415 U.S. 61, 94 S. Ct. 937 (1974)

Rule:

The temporary loss of income, ultimately to be recovered, does not usually constitute irreparable injury. The key word in this consideration is irreparable. Mere injuries, however substantial, in terms of money, time and energy necessarily expended in the absence of a stay, are not enough. The possibility that adequate compensatory or other corrective relief will be available at a later date, in the ordinary course of litigation, weighs heavily against a claim of irreparable harm.

Facts:

Upon being notified that she was going to be discharged on a specific date from her position as a probationary Government employee, Murray 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.

Issue:

Was the District Court's issuance of the temporary injunctive relief proper?

Answer:

No

Conclusion:

The Court held that Murray’s showing fell far short of the "irreparable injury" required to justify issuance of a restraining order temporarily enjoining respondent's termination from employment with the General Services Administration. Murray contended that her termination was based in part on her activities while in the course of her previous employment in the Defense Intelligence Agency, and that she was therefore entitled to an opportunity to file an answer. The Court held that Murray, at the very least, had to make a showing of irreparable injury sufficient in kind and degree to override the factors that cut against the general availability of preliminary injunctions in government personnel cases. The Court disagreed that either loss of earnings or damage to reputation would afford a basis for a finding of irreparable injury and thus provide a basis for temporary injunctive relief. Therefore, the Court reversed the decision of the lower court.