from the release notes of WCS 4.1.191.
"In order to be compatible, the Cisco WCS release must be at least the same release or a later release than
the software release running on the controller. For example, Cisco WCS running release 4.0 cannot
manage a controller running release 4.1. If an upgrade is planned, upgrade the Cisco WCS first to
eliminate any unexpected issues. Cisco WCS supports database upgrades only from the following
official Cisco WCS releases:"
I have always upgraded the controllers 1st, and then the server; all the way up to 4.2.112.0. That may change in the future though...
