Ingraham v. Wright

Following is the case brief for Ingraham v. Wright, 430 U.S. 651 (1977)

Case Summary of Ingraham v. Wright:

  • Corporal punishment was allowed in Florida schools, provided that the punishment was not “degrading or unduly severe.”
  • Two students at a Florida middle school were subjected to particularly harsh corporal punishment.
  • Families of the students filed a federal suit against the middle school’s principals and school system, alleging that the corporal punishment violated the children’s constitutional rights.
  • The District Court dismissed the case, and the Court of Appeals affirmed.
  • The U.S. Supreme Court also affirmed, holding that the Eighth Amendment does not apply to corporal punishment in schools, and that due process does not require notice and a hearing prior to imposing punishment.

Ingraham v. Wright Case Brief

Statement of the Facts:

Two students, James Ingraham and Roosevelt Andrews were subjected to particularly harsh corporal punishment for minor infractions at the Charles R. Drew Junior High School.  The people administering the punishments were the school’s principal and assistant principals.

Florida law allowed corporal punishment that was not “degrading or unduly severe,” suggesting as appropriate hitting a child’s rear with a paddle five times.  Ingraham, however, was struck 20 times by the school principal to the point where Ingraham needed medical attention.  Andrews was paddled several times and also hit on the arms, which left an injury that lasted a week.

The families of the children filed suit against the administrators and school system in federal court.  The suit alleged that the punishment violated the children’s constitutional rights.

Procedural History:

  • The District Court, after a trial, found no constitutional basis for relief. It noted that the punishment did not rise to cruel and unusual punishment and dismissed the suit.
  • On appeal, one panel of the Fifth Circuit Court of Appeals voted to reverse.
  • However, after a rehearing before the Fifth Circuit en banc, the Fifth Circuit agreed with the District Court.
  • The U.S. Supreme Court granted certiorari.

Issue and Holding:

Does corporal punishment in public school violate the Eighth Amendment as cruel and unusual punishment, or the Fourteenth Amendment’s Due Process Clause?  No.

Judgment:

The decision of the Fifth Circuit Court of Appeals is affirmed.

Rule of Law or Legal Principle Applied:

The Eighth Amendment’s prohibition of cruel and unusual punishment does not apply to corporal punishment in public schools, nor does due process require notice and a hearing before imposing such punishment.

Reasoning:

The history of the Eighth Amendment demonstrates that the prohibition of cruel and unusual punishment was meant to apply to criminals, not school children.  Further, the openness of public schools and the community’s supervision of schools provide enough safeguards against excessive discipline of children.  Moreover, if a punishment is too harsh, then an administrator is liable in civil or criminal court.

With regard to due process, the practice of corporal punishment is limited by the common law.  Therefore, the Fourteenth Amendment’s Due Process Clause does not require notice and a hearing before imposing corporal punishment.  The Florida corporal punishment law provides significant protection against unjustified corporal punishment.  Adding constitutional requirements intrudes too far into the State’s educational responsibilities.

Concurring and Dissenting Opinions:

Dissenting Opinion (White):

The Court is wrong to rule out the Eighth Amendment entirely.  It is possible that corporal punishment can be so severe that it implicates the Eighth Amendment’s prohibition on cruel and unusual punishment.  Essentially, punishment is punishment regardless of whether it is in the criminal context or in school.  Thus, the Eighth Amendment can apply.

Further, students should be entitled to some type of hearing before having a beating inflicted upon them.  They should at least be allowed to provide their side of the story.

Dissenting Opinion (Stevens):

Justice White’s analysis is correct.  It is important to add that, with regard to due process, a remedy for a due process violation after there was a deprivation of liberty may be sufficient.

Significance:

Ingraham v. Wright is a landmark case because it held that corporal punishment in public school could not violate the Eighth Amendment’s prohibition of cruel and unusual punishment.  To this day, there are still some states that allow corporal punishment in public schools.  In addition, corporal punishment is legal in private schools in every state except New Jersey and Iowa.

Student Resources:

Read the Court’s Full Opinion

Listen to the Oral Arguments

 

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