Ingraham v. Wright

No. 75-6527 Argued: November 2, 1976 --- Decided: April 19, 1977

Summary

Two Florida students who were paddled in school brought suit in federal court arguing that the paddling was “cruel and unusual punishment” and that students should have a right to be heard before physical punishment is given. They lost in the trial court and at the Court of Appeals, and then appealed to the Supreme Court.

Petitioners: James Ingraham and Roosevelt Andrews

Respondents: Willie J. Wright, et al.

Petitioners' Claim: That officials at Drew Junior High School violated the Eighth and Fourteenth Amendments by spanking them.

Chief Lawyer for Petitioners: Bruce S. Rogow

Chief Lawyer for Respondents: Frank A. Howard, Jr.

Justices for the Court: Harry A. Blackmun, Warren E. Burger, Lewis F. Powell, Jr., William H. Rehnquist, Potter Stewart

Decision: The Supreme Court dismissed the case against Drew Junior High School, saying the school did not violate the students' constitutional rights.

Justices Dissenting: William J. Brennan, Jr., Thurgood Marshall, John Paul Stevens, Byron R. White

Date of Decision: April 19, 1977

One of the issues concerning the court was the eighth amendment. It states “ that cruel and unusual punishment is prohibited.” ( McClenaghan, 772) Although the admendment doesn’t apply to paddling in school, the United States Supreme Court stated that the amendment is meant to protect people convicted of crimes against the state and not students with disciplinary problems.

Significance

With Ingraham, the Court said corporal punishment, or spanking, is not cruel and unusual punishment. It also said schools can use corporal punishment without giving students a chance to explain their conduct or otherwise defend themselves. If a student is injured by corporal punishment, he may file civil or criminal charges against the school.

When a defendant is found guilty after a criminal trial, the Eighth Amendment prevents the government from using cruel and unusual punishments—punishments that are barbaric in a civilized society. Under the Due Process Clause of the Fourteenth Amendment, states must obey the Eighth Amendment and avoid cruel and unusual punishments.

The American justice system is supposed to be fair. When a person is accused of breaking a law, fairness means giving him notice of the charges against him. Fairness also means holding a hearing or trial to give the accused a chance to defend himself. Notice and a hearing are part of "due process of law." The Fourteenth Amendment requires states to use due process of law before taking away a person's liberty or freedom.

Public schools often punish students who misbehave in school. The punishment can be detention, suspension, expulsion, or corporal punishment. Corporal punishment is punishment inflicted on a student's body, such as spanking. In Ingraham v. Wright, the Supreme Court had to decide whether corporal punishment is cruel and unusual under the Eighth Amendment. The Court also had to decide whether schools must give students notice and a hearing before using corporal punishment.

Paddle Licks

In the early 1970s, a Florida law allowed public schools to use corporal punishment to maintain discipline. In Dade County, Florida, a local law said teachers could punish students using a flat wooden paddle measuring less than two feet long, three to four inches wide, and one-half inch thick. Teachers were supposed to get permission from the principal before paddling a student, and then were supposed to limit the paddling to one to five licks on the student's buttocks. Teachers, however, paddled students without getting permission and used more than five licks.

During the 1970-71 school year, James Ingraham and Roosevelt Andrews were students at Drew Junior High School in Dade County. On one occasion in October 1970, Ingraham was slow to respond to his teacher's instructions. As punishment, Ingraham received twenty licks with a paddle while being held over a table in the principal's office. The paddling was so severe that Ingraham missed several days of school with a hematoma, a pool of blood in his buttocks.

Ingraham and Roosevelt filed a lawsuit against the principals of Drew Junior High and the superintendent of the Dade County School System. Ingraham and Roosevelt thought the school violated the Eighth Amendment by using cruel and unusual punishment and the Fourteenth Amendment by paddling them without a hearing. Ingraham and Roosevelt wanted to recover damages and to prevent the school from using corporal punishment in the future. The trial court dismissed the lawsuit, however, and the court of appeals affirmed, so the students took their case to the U.S. Supreme Court.

The Court's Decision

In a 5-4 decision, the Supreme Court decided that public school students could be paddled without first receiving a hearing.

Writing for the Court, Justice Lewis F. Powell, Jr., first addressed whether the Eighth Amendment applies to public schools. The Eighth Amendment says, "Excessive bail shall not be required, nor excessive fines imposed, nor cruel and unusual punishments inflicted." Powell said bail, fines, and punishment are part of the criminal justice system. Public schools are not part of that system, so they do not have to obey the Eighth Amendment.

Bruce S. Rogow, Ingraham and Roosevelt's lawyer, urged the court to apply the Eighth Amendment to corporal punishment in public schools. He said there were few public schools when the United States adopted the amendment in 1791 because most children were educated privately. Americans did not know that someday students would be forced to attend public schools in which corporal punishment would be used. Rogow said it would be absurd to protect criminals but not school children from cruel and unusual punishment.

Attorney Rogow also argued that schools should have to give students a hearing and a chance to defend themselves before using corporal punishment. After all, in Goss v. Lopez (1975), the Supreme Court said schools must give students notice and a hearing before suspending them from school for up to ten days. Students should get the same due process rights before being paddled.

The Supreme Court also rejected this argument. Florida laws allowed students who were injured by severe beatings to sue school officials to recover their damages. School officials also could face criminal charges in such cases. Justice Powell said civil and criminal charges are enough to protect students who receive beatings that are unfair or too harsh. Forcing schools to hold a hearing in every case would make corporal punishment too expensive and time-consuming. The Supreme Court was not willing to end corporal punishment by making it so costly.

Ingraham is one of a series of cases in which the Supreme Court has struggled to find the proper balance between the rights of individual students and the needs of school officials to maintain order to protect the rights of students as a group.

Ingraham v. Wright

That same month, school officials paddled Andrews several times for breaking minor school rules. On two occasions the school paddled Andrews on his arms. One paddling was so bad that Andrews lost full use of his arm for a week. Other students also received severe paddlings. One student got fifty licks for making an obscene telephone call.