In the case of Honig v. Students of the California School for the Blind, 1984, Superintendent Honig and other officials were sued by students from two schools for visually impaired children in California. The students claimed that their rights under Section 504 of the Rehabilitation Act had been violated because they were not provided with a free appropriate public education (FAPE). They argued that this was due to inadequate funding and staffing levels at their schools. The Supreme Court ruled in favor of the students, stating that all disabled individuals have a right to FAPE as mandated by federal law regardless of state budget constraints or administrative convenience. This landmark decision reinforced protections for disabled students across America and emphasized states' responsibilities towards them.

In the dissenting opinion for Honig v. Doe, Justice White argued that the majority's interpretation of the Education of All Handicapped Children Act (EAHCA) was too broad and would lead to disruptive students being kept in classrooms at the expense of other students' education. He believed that school officials should have more discretion when it comes to disciplining disabled students who are violent or disruptive, especially if their behavior is not related to their disability. Furthermore, he expressed concern about forcing schools to continue providing educational services for suspended or expelled students as this could strain resources and potentially lower educational standards. Overall, while acknowledging the importance of protecting disabled children’s rights, he emphasized a need for balance with maintaining an effective learning environment.