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Ingraham v. Wright
3
Ingraham v. Wright
75-6527
Facts
On October 1, 1970, Assistant Principal Solomon Barnes applied corporal punishment to Roosevelt Andrews and fifteen other boys in a restroom at Charles R. Drew Junior High School. A teacher had accused Andrews of tardiness, but Andrews claimed he still had two minutes to get to class when he was seized. When Andrews resisted paddling, Barnes struck him on the arm, back, and across the neck.
Facts
On October 6, 1970, Principal Willie J. Wright removed James Ingraham and several other disruptive students to his office, where he paddled eight to ten of them. When Ingraham refused to assume a paddling position, Wright called on Barnes and Assistant Principal Lemmie Deliford to hold Ingraham in a prone position while Wright administered twenty blows. Ingraham’s mother later took him to a hospital for treatment, where he was prescribed cold compresses, laxatives and pain-killing pills for a hematoma.
FACTS
Ingraham and Andrews filed a complaint against Wright, Deliford, Barnes and Edwart L. Whigham, the superintendant of the Dade County School System; the complaint alleged the deprivation of constitutional rights and damages from the administration of corporal punishment. They also filed a class action for declaratory and injunctive relief on behalf of all students in the Dade County schools. At the close of Ingraham and Andrews’ case, the defendants successfully moved to dismiss the third count because the plaintiffs showed no right to relief. The court also ruled that the evidence for the first two counts was insufficient to go to a jury. The United States Court of Appeals, Fifth Circuit, reversed. The Fifth Circuit held that the punishment of Ingraham and Andrews was so severe that it violated the Eighth and Fourteenth amendments and that the school’s corporal punishment policy failed to satisfy due process. Upon rehearing, the en banc court rejected this conclusion and affirmed the judgment of the trial court. It held that due process did not require that students receive notice or an opportunity to be heard and that the Eighth and Fourteenth Amendments do not forbid corporal punishment in schools.
Does the cruel and unusual punishment clause of the Eighth Amendment forbid corporal punishment inflicted by teachers and administrators upon Ingraham and Andrews at Charles R. Drew Junior High School? Does Dade County School System’s corporal punishment policy violate due process?
Question
Plaintiff
PETITIONER
James Ingraham, Roosevelt Andrews
Ingraham
ADVOCATES
Bruce S. Rogow
Defense
Willie J. Wright, Lemmie Deliford, Solomon Barnes, Edward L. Whigham
Wright
ADVOCATES
Frank A. Howard, Jr.
Verdict
In a 5-4 decision written by Justice Lewis Powell, the Court held that the Eighth Amendment does not prevent corporal punishment in public schools. While acknowledging the general abandonment of corporal punishment as a means of punishing criminals, Justice Powell looked to the common law history of similar punishment in schools and discerned no trend towards its elimination. Rather, common law suggested that teachers could legally impose reasonable, non-excessive force on their students. He also noted that the Court previously limited the application of the Eighth Amendment’s “cruel and unusual” language to criminal punishment. Justice Powell reasoned that Ingraham and Andrews had less need for similar Eighth Amendment protection because they attended an open institution subject to more public scrutiny.
Justices
Harry A. Blackmun, Warren E. Burger, Lewis F. Powell, Jr., William H. Rehnquist, Potter Stewart