Ingraham v. Wright

PETITIONER: James Ingraham, Roosevelt Andrews
RESPONDENT: Willie J. Wright, Lemmie Deliford, Solomon Barnes, Edward L. Whigham
LOCATION: Charles R. Drew Middle School, formerly Charles R. Drew Junior High School

DOCKET NO.: 75-6527
DECIDED BY: Burger Court (1975-1981)
LOWER COURT: United States Court of Appeals for the Fifth Circuit

CITATION: 430 US 651 (1977)
ARGUED: Nov 02, 1976 / Nov 03, 1976
DECIDED: Apr 19, 1977
GRANTED: May 24, 1976

ADVOCATES:
Bruce S. Rogow - for petitioners
Frank A. Howard, Jr. - for respondents

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 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.

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.

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.

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?

Media for Ingraham v. Wright

Audio Transcription for Oral Argument - November 02, 1976 in Ingraham v. Wright
Audio Transcription for Oral Argument - November 03, 1976 in Ingraham v. Wright

Audio Transcription for Opinion Announcement - April 19, 1977 in Ingraham v. Wright

Warren E. Burger:

The judgment and opinion of the Court in 75-6527, Ingraham against Wright will be announced by Mr. Justice Powell.

Lewis F. Powell, Jr.:

This case presents questions concerning the use of corporal punishment in the public schools. Petitioners were junior high school students in Dade County Florida.

They brought this suit in the United States District Court against school officials alleging deprivation of constitutional rights and seeking damages and injunctive relief.

At trial, petitioner's evidence indicated that they were severely paddled for relatively minor infractions of rules.

One of the petitioners were subjected to more than 20 licks resulting in serious bruising and absence from school for 11 days.

Florida law in keeping with the common law authorizes reasonable corporate punishment as a means of maintaining discipline but such punishment may not be degrading or unduly severe and may not be inflicted or maybe inflicted only after prior consultation with the school officials.

Although the evidence offered by petitioners was indicated are violations of Florida law, the District Court found no violation of federal constitutional right.

The suit was dismissed without hearing evidence from the school authorities.

The Court of Appeals for the Fifth Circuit affirmed and we granted certiorari.

Petitioners alleged two violations of constitutional rights.

They first assert with the Eighth Amendment's prohibition of cruel and unusual punishment applies to school punishment as well as to that imposed under the criminal law.

The use of corporal punishment to discipline school children dates back to colonial times.

The law was then well settled but teachers had this right so long as excessive force was not used.

The founding fathers were familiar with this practice and with common laws.

Nor has a law been changed in 187 years since the adoption of the Eighth Amendment, 23 States have addressed this issue through legislation, 21 have reaffirmed the substance of the common law rule.

Only two States have prohibited physical punishment in the public schools.

In some, we find no basis for wrenching the Eighth Amendment from its historical context and extending it to school discipline.

Petitioners further contend that they were entitled by virtue of the Due Process Clause of the Fourteenth Amendment to a hearing before being paddled.

We agreed with petitioners that are protected liberty interest is implicated when school authorities restrain a pupil and inflict appreciable physical pain.

But the possible violation of a constitutional right does not always require a prior hearing.

The basic question is whether other remedies long available or adequate to provide reasonable protection of the right.

The remedies here are substantial.

The common law allows the pupil to recover damages from a teacher who imposes excessive punishment.

Florida statutes also imposed both criminal and civil liabilities.

Moreover, in the openness of a public school with a restraining presence of pupils and other teachers, the risk of excessive punishment is slight.

Indeed, the evidence in this case indicated that the punishment inflicted on petitioners was quite unusual.

Common sense as well as long experience tells us that the risk of abuse of this traditional disciplinary measure is minimal and when abused, the consequences for the offending teachers can be serious indeed.

We found therefore, no basis in the constitution for commanding a prior hearing.

The remedy is already available have been accepted as adequate to protect children since the founding of this country.

We decline at this late date and at a time when serious problems be set out of schools to impose an unnecessary restriction on all school teachers simply because a misconduct of a few in one school in Florida.