In Garnett v. Renton School Dist., 772 F. Supp. 531, 534 (W.D.Wash. 1991), rev'd on other grounds, 987 F.2d 641 (9th Cir. 1993), cert. denied, 510 U.S. 819, 126 L. Ed. 2d 41, 114 S. Ct. 72 (1993), on remand, 1994 U.S. App. LEXIS 8887, 1994 WL 555397 (W.D. Wash. 1994), appeal after remand, 21 F.3d 1113 (9th Cir. 1994), the federal district court determined that Future Business Leaders of America (FBLA) was a noncurriculum-related student group meeting at the school and, therefore, the school's refusal to also permit a Bible Club to meet during noninstructional time violated the EAA.

School district and state guidelines required that FBLA be offered, but business class students were not required to attend and no academic credit was awarded for participation. The court stated that in such a circumstance where a club such as FBLA is required to be offered, the options open to a school to avoid a limited open forum under the EAA are restricted: "adjust class requirements, provide instruction in FBLA meetings, or drop business classes." 772 F. Supp. at 534.