Wadsworth v. California Department of Corrections and Rehabilitation

Background

Christopher Stewart Wadsworth asked for a temporary restraining order, or TRO, to prevent the California Department of Corrections and Rehabilitation (CDCR) from carrying out an absent-without-leave termination scheduled for June 27, 2025. He also asked the court to restore his employment status, compensation, benefits, and the four-day, ten-hour work schedule described in a 2017 settlement agreement.

The settlement agreement required CDCR to transfer Wadsworth to a Staff Psychiatrist position at Folsom State Prison with a four-day, ten-hour schedule effective January 1, 2018. The parties had agreed to dismiss the earlier claims with prejudice, but the court retained jurisdiction to ensure compliance with the settlement agreement. The court had previously found the schedule provision clear and unambiguous.

Wadsworth alleged that, beginning in February 2024, CDCR placed him in mailroom positions and assigned him to work five days per week, contrary to the settlement agreement. CDCR responded that the four-day, ten-hour schedule applied when Wadsworth was performing duties as a Staff Psychiatrist and that the schedule was not appropriate while he was assigned to the mailroom. Evidence submitted to the court also indicated that, as of at least May 5, 2025, Wadsworth was not complying with requirements for retaining a Staff Psychiatrist position.

CDCR’s termination letter stated that Wadsworth had been absent without approved leave for five consecutive working days, from June 11 through June 17, 2025. Wadsworth disputed those facts and requested a hearing under the applicable California absence-without-leave procedure. The court said it did not know whether that hearing had occurred or would occur.

Legal standard

To obtain a TRO, a plaintiff must show a likelihood of success on the underlying issue, likely irreparable harm without immediate relief, that the hardships favor an injunction, and that an injunction would serve the public interest. The court may use a balancing approach, but it still requires the plaintiff to make the required showing. Because the government was a party, the court treated the hardship and public-interest factors together.

Court’s analysis

The court found that Wadsworth had not described harm that could not be remedied through a legal remedy such as damages or back pay. The possible loss of employment and income therefore did not establish irreparable harm on the record presented.

The court recognized Wadsworth’s interest in enforcing the settlement agreement. But it found that he had not connected the planned absent-without-leave termination to that agreement. The court also noted that Wadsworth alleged noncompliance for more than a year and that he appeared to have rights under California law concerning the termination. The court concluded that the balance of hardships did not strongly favor Wadsworth.

Regarding likely success, Wadsworth argued that CDCR’s alleged failure to follow the settlement agreement led to the termination and caused him to lose the ability to use paid leave for missed days. The court observed that the termination letter cited five consecutive days of absence without approved leave and that the evidence indicated Wadsworth was not meeting the qualifications for the Staff Psychiatrist position. The court stated that the apparent grounds for the termination were unrelated to the settlement agreement’s four-day, ten-hour schedule provision.

The parties also disagreed about the meaning and duration of that provision. CDCR argued that it required a transfer with the schedule in 2018 and did not guarantee that schedule in all later circumstances, including if Wadsworth failed to meet professional training or licensing requirements. Wadsworth argued that he was entitled to the schedule throughout his employment and that the agreement had no time limit. The court did not resolve that dispute in this order.

The court acknowledged California’s public policy favoring enforcement of settlement agreements, but concluded that the requested TRO concerning the absent-without-leave termination appeared disconnected from the settlement agreement.

Disposition

The court denied Wadsworth’s TRO. It scheduled a July 17, 2025 hearing on his motion to enforce the settlement agreement and ordered him to file a reply by July 3, 2025.