Food Service Dynamics, Inc. v. Ambach

Summary

The court reversed a judgment granting petitioners relief in an Article 78 proceeding concerning New York’s administration of a federal summer feeding program. It held that food service management companies lacked standing because the program was not intended to benefit the food service business and the petitioners were outside the relevant statutory zone of interests.

Holdings

1. Petitioners lacked standing to maintain the article 78 proceeding because Congress did not create the summer feeding program to benefit the food service business.

Questions Presented

1. Whether food service management companies that prepared and delivered meals under contracts with program sponsors had standing to bring a CPLR article 78 proceeding compelling the administering agency to process reimbursement claims and pursue federal funding.
2. Whether petitioners fell within the statutory zone of interests protected by the National School Lunch Act and Child Nutrition Act because their businesses were economically affected by the agency's failure to process program reimbursements.

Disposition

reversed