Pupils in a Dade County, Florida, junior high school filed for damages against school officials, claiming that students had been subjected to disciplinary corporal (physical) punishment in violation of their constitutional rights. At that time, the Florida law allowed corporal punishment after the teacher had consulted with the school principal, stating that the punishment was not to be "degrading or unduly severe." A School Board regulation contained specific directions and limitations, authorizing hitting a student's buttocks with a wooden paddle. The evidence showed that the paddling of petitioners was exceptionally harsh. The District Court granted the school's motion to dismiss the complaint. The Court of Appeals affirmed.
1. The Cruel and Unusual Punishments Clause of the Eighth Amendment does not apply to disciplinary corporal punishment in public schools.
(a) The history of the Eighth Amendment and the decisions of this Court make it clear that the prohibition against cruel and unusual punishment was designed to protect those convicted of crime.
(b) There is no need to extend the Eighth Amendment from its historical context to public school disciplinary practices. The openness of the public school and its supervision by the community provide safeguards against the kinds of abuses from which that Amendment protects convicted criminals.
2. The Due Process Clause of the Fourteenth Amendment does not require notice before use of corporal punishment.
(a) Liberty within the meaning of the Fourteenth Amendment applies where public school authorities deliberately punish a child by restraint and physical pain.
(b) Corporal punishment is limited. Procedural safeguards minimize the risk of wrongful punishment.
(c) The Florida scheme affords significant protection against unjustified corporal punishment of school children. The teacher and principal must exercise judgment when using corporal punishment.
(d) The educational responsibility lies primarily with the school authorities.
Source: Ingraham v. Wright Link 2
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