3:15-cv-02322
N.D. Cal.Jun 26, 2025Background:
- In June 2017, Plaintiff Stewart Wadsworth and Defendants (including CDCR) entered into a settlement agreement that required transferring Wadsworth to a Staff Psychiatrist position at Folsom State Prison on a 4/10 schedule and dismissed his prior claims, with the court retaining jurisdiction to enforce the agreement.
- In 2024, Wadsworth alleges CDCR assigned him to mailroom duties and a standard 5-day workweek, violating the terms of the settlement, and he repeatedly complained to CDCR about this change.
- In 2025, Wadsworth was placed on Administrative Time Off and used FMLA leave; however, there is no explanation for this removal and alternate assignment.
- On June 18, 2025, CDCR notified Wadsworth of its intention to terminate him for being Absent Without Official Leave (AWOL) for five consecutive days (June 11–17, 2025), giving him an opportunity for a "Coleman" hearing.
- Wadsworth sought a Temporary Restraining Order (TRO) to prevent the AWOL termination and enforce the 4/10 schedule, alongside related relief and reinstatement pending further proceedings.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether irreparable harm exists justifying TRO | Loss of employment, financial harm, and loss of benefits | Harm compensable by damages; no irreparable harm | No irreparable harm; legal remedies available |
| Relationship between AWOL termination and settlement | AWOL is a result of CDCR’s breach of the 4/10 work schedule | AWOL based on Stewart’s 5-day unexcused absence | AWOL termination not shown to stem from breach |
| Whether Plaintiff likely to succeed on merits of TRO | Noncompliance with the settlement caused employment issues | Terms of 4/10 schedule don’t apply unless acting as psychiatrist; Plaintiff not in compliance with job requirements | Unlikely to succeed on merits; ambiguous link |
| Balance of hardships/public interest | Plaintiff needs enforcement of contract and prevention of harm | CDCR needs to enforce workplace rules and operational needs | Balance does not tip in Plaintiff’s favor |
Key Cases Cited
- Winter v. Nat. Res. Def. Council, 555 U.S. 7 (U.S. 2008) (sets the standard for granting preliminary injunctive relief)
- Garcia v. Google, Inc., 786 F.3d 733 (9th Cir. 2015) (likelihood of success on the merits is the most important factor)
- Sampson v. Murray, 415 U.S. 61 (U.S. 1974) (loss of employment alone does not constitute irreparable harm)
- Alliance for the Wild Rockies v. Cottrell, 632 F.3d 1127 (9th Cir. 2011) (sliding scale for TRO standards in Ninth Circuit)
- Drakes Bay Oyster Co. v. Jewell, 747 F.3d 1073 (9th Cir. 2014) (where government is a party, public/private interests merge)