Sampson v. Murray

LOCATION:Bureau of Indian Affairs

DOCKET NO.: 72-403
DECIDED BY: Burger Court (1972-1975)
LOWER COURT: United States Court of Appeals for the District of Columbia Circuit

CITATION: 415 US 61 (1974)
ARGUED: Nov 14, 1973
DECIDED: Feb 19, 1974

Keith A. Jones – for petitioners
Thomas McGrew – for respondent, pro hac vice, by special leave of Court

Facts of the case


Media for Sampson v. Murray

Audio Transcription for Oral Argument – November 14, 1973 in Sampson v. Murray

Audio Transcription for Opinion Announcement – February 19, 1974 in Sampson v. Murray

Warren E. Burger:

Mr. Justice Rehnquist will announce the opinions in Sampson against Murray and Winward Shipping against American Radio Association.

William H. Rehnquist:

The case of Sampson against Murray kind of came to us from the Court of Appeals for the District of Columbia Circuit.

Respondent Sampson was a probationary government employee in the public building services of GSA.

She was notified by her supervisor that she would be discharged from employment at a specified future date.

Pending her administrative appeal for the civil service commission, she sought a temporary restraining order in United States District Court, claiming that she had been dismissed for reasons pertaining to her previous employment and that she had not received the procedural protection required by the civil service regulations for dismissals of that type.

The district judge issued a temporary restraining order and set a hearing on the motion for preliminary injunction for the following week.

At that time the government refused to produce a witness and offered his testimony by affidavit.

The District Court said that he wished to hear the witness in person and rejected the government’s offer to proceed by affidavit.

When the government indicated they would not produce the supervisor, the District Court announced that the temporary restraining order would be indefinitely continued.

The Court of Appeals for the District of Columbia Circuit affirmed the District Court, holding that the lower court could properly issue such an injunctive order to preserve the status quo, pending respondent’s pursuit of administrative remedy.

While we don’t believe that the District Court is without jurisdiction to issue temporary injunctions in government personnel cases, we think that several factors militated against the granting of relief in a case such as this and that temporary relief should be reserved for truly extraordinary cases.

We hold the federal courts in general and this Court in particular has had a traditional reluctance to intervene in government personnel disputes, involving as they do, the often delicate relationship of employer and employee and the important considerations of government efficiency.

This reluctance has increased in the case when the employee is a probationary employee, a class of employee to whom Congress has extended fewer substantive and procedural rights than to permanent employees.

When the discharge of such employees is at issue we believe the District Court should play a very restricted role leaving the matter to the Civil Service Commission in all but the most exceptional circumstances until that Commission has had an opportunity to review the validity of a discharge and to contemplate the proper relief if needed.

We accordingly reverse the judgment of the Court of Appeals for the District of Columbia Circuit.

Mr. Justice Marshall has filed a dissenting opinion in which Mr. Justice Brennan has joined.

Mr. Justice Douglas has filed a dissenting opinion.