In the case of Sampson, Administrator, General Services Administration, et al. v. Murray (1973), a probationary federal employee was terminated from her position and sought injunctive relief to prevent her dismissal while she appealed through administrative channels. The Supreme Court held that unless an employee can show irreparable injury or a violation of constitutional rights, they are not entitled to judicial intervention in their termination process before exhausting all administrative remedies provided by Civil Service Commission regulations. This decision reinforced the principle that courts should be reluctant to interfere with personnel decisions within government agencies unless there is clear evidence of wrongdoing or harm.

In the dissenting opinion for Sampson, Administrator, General Services Administration v. Murray (1973), Justice Douglas argued that the majority's decision undermined civil service protections and due process rights of federal employees. He contended that a stay should have been granted to prevent irreparable harm to Ms. Murray while her case was being reviewed by an appellate court - especially considering she had already won at trial level. The majority’s refusal to grant this relief essentially rendered any subsequent victories meaningless as she would have already lost her job and suffered associated damages such as loss of income and reputation damage in the interim period between trials. Furthermore, he criticized the majority's reliance on sovereign immunity doctrine which he believed was outdated and irrelevant in modern administrative law context where government agencies are expected to respect individual rights just like private entities.