## Facts

- Congress authorized the federal School Breakfast Program, providing subsidies to participating schools under federal conditions; participation by states and local school districts was voluntary.
- Texas enacted a statute requiring certain school districts to participate in the federal breakfast program when a specified percentage of students qualified for reduced-price breakfasts.
- Garland Independent School District (GISD) met the statutory threshold but decided not to participate, citing expected financial and administrative burdens.
- Texas education officials sought to enforce the state statute against GISD.
- GISD sued state officials in federal court, seeking declaratory and injunctive relief on the ground that the state mandate conflicted with the federal scheme and was invalid under the Supremacy Clause.

## Issues

1. Whether a school district, as a political subdivision of the state, has standing to sue state officials in federal court alleging that a state statute interferes with a choice conferred on the district by federal law.
2. Whether Texas’s compulsory-participation requirement is preempted under the Supremacy Clause because federal law and regulations treat participation in the School Breakfast Program as voluntary.

## Decision

- The Fifth Circuit affirmed the district court’s judgment for GISD.
- The court held GISD had standing because it alleged concrete injury and asserted that state law interfered with a federally conferred option.
- The court held the Texas statute conflicted with the federal program’s voluntary structure and was therefore invalid under the Supremacy Clause as applied to covered school districts.
- State officials could not enforce the compulsory-participation requirement against GISD.

## Legal Principles

- A political subdivision may have standing to sue state officials when it alleges that a state statute interferes with the exercise of a power or option conferred on it by federal law and the subdivision shows injury in fact.
- Older “creature of the state” limits on municipal challenges generally concern assertions of the subdivision’s own constitutional rights against the state, not Supremacy Clause claims tied to a federal statutory scheme granting the subdivision a defined role.
- State law is preempted when it conflicts with federal law, including when it removes a choice Congress left to local actors and thereby frustrates federal objectives.

## Conclusion

The Fifth Circuit held that a Texas school district could sue state officials to vindicate a federally conferred choice and that Texas’s statute compelling participation in the federal School Breakfast Program was preempted because federal law made participation voluntary.


Rogers v. Brockette, 588 F.2d 1057 (5th Cir. 1979)