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. Andrews claimed he still had two minutes to get to class. When Andrews resisted the paddling, Barnes struck him on the arm, back, and neck.

Five days later, Principal Willie J. Wright removed James Ingraham and several other disruptive students to his office, where he paddled them. When Ingraham refused to bend over, Wright called the Assistant Principal to hold Ingraham 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 use of corporal punishment. The court ruled that the evidence was insufficient to go to a jury. The United States Court of Appeals reversed the decision. The court 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. During a rehearing, the court rejected this conclusion and affirmed the original judgment. It held that due process did not require that students receive notice or have an opportunity to be heard.

Conclusion: In a 5-4 decision written by Justice Louis Powell, the Court held that the cruel and unusual punishment clause of the Eighth Amendment does not prevent corporal punishment in public schools. Justice Powell looked to the common law history of similar punishment in schools, where he did not find any trend towards its elimination. Common law suggested that teachers could legally impose reasonable 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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