Ingraham v. Wright (1977) #2

Facts of the case: On October 1, 1970, Assistant Principal Solomon Barnes applied corporal punishment to Roosevelt Andrews and fifteen other boys in a restroom at a 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.

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 the Assistant Principal to hold Ingraham in a prone position while Wright administered twenty blows. Ingraham’s mother later took him to a hospital for treatment.

Ingraham and Andrews filed a complaint alleging the deprivation of constitutional rights and damages from the administration of corporal punishment. The court ruled that the evidence 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.

Question: 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?

Conclusion: No and no. In a 5-4 decision written by Justice Louis 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.

Source: Ingraham v. Wright (1977) #2
"Ingraham v. Wright." Oyez, https://www.oyez.org/cases/1976/75-6527. Accessed 9 Jun. 2017

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