Heimberger v. School District of Saginaw

881 F.2d 242 (1989)

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Heimberger v. School District of Saginaw

United States Court of Appeals for the Sixth Circuit
881 F.2d 242 (1989)

Facts

Fuerbringer Elementary School in the school district of Saginaw (Saginaw) (defendant) implemented disciplinary Policy #1, under which students who misbehaved twice or more during a lunch period would be temporarily suspended from the period. As a result of the lunch-period suspension, students could not obtain their government-subsidized lunches. Parents of three Fuerbringer students (the students) (plaintiffs) complained about Policy #1. The school implemented revised Policy #2, under which students would be temporarily suspended from lunch periods if they misbehaved three or more times. Policy #2 allowed suspended students to eat their school lunch if accompanied by a supervising parent. If a parent failed to attend and did not provide sufficient reasoning for not attending, the student was sent home without a subsidized lunch. The students filed a class-action suit challenging the policies. Thereafter, Saginaw temporarily implemented Policy #3, under which students who would have received penalties under Policy #2 were subject to a full-day suspension rather than just for the lunch period. The students moved for summary judgment. The court granted the motion, finding that Policies #1 and #2 violated the National School Lunch Act (NSLA) and the Child Nutrition Act (CNA) by directly depriving the students of subsidized school lunches as a form of discipline. The district court based its decision on the interpretation of the statutes by the United States Department of Agriculture, which concluded that directly denying a subsidized meal as a form of discipline violates the law. However, disciplinary measures that indirectly lead to the loss of subsidized meals, such as through a full-day suspension, would not be inconsistent with the law. Based on this reasoning, the students acknowledged and the court concluded that Policy #3 was not in violation of the NSLA or CNA. Saginaw appealed, arguing that the students lacked standing because the injury of a threatened loss of school lunch would not be addressed by the declaratory and injunctive relief sought.

Rule of Law

Issue

Holding and Reasoning (Brown, J.)

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