Ingraham V. Wright
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''Ingraham v. Wright'', 430 U.S. 651 (1977), was a United States
Supreme Court In most legal jurisdictions, a supreme court, also known as a court of last resort, apex court, high (or final) court of appeal, and court of final appeal, is the highest court within the hierarchy of courts. Broadly speaking, the decisions of ...
case that upheld the disciplinary
corporal punishment A corporal punishment or a physical punishment is a punishment which is intended to cause physical pain to a person. When it is inflicted on Minor (law), minors, especially in home and school settings, its methods may include spanking or Padd ...
policy of
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's
public schools Public school may refer to: *Public school (government-funded), a no-fee school, publicly funded and operated by the government *Public school (United Kingdom), certain elite fee-charging private schools in England and Wales *Great Public Schools, ...
by a 5-4 vote. The Court also held that the Eighth Amendment did not apply to corporal punishment, and that the
Due Process Clause A Due Process Clause is found in both the Fifth and Fourteenth Amendments to the United States Constitution, which prohibit the deprivation of "life, liberty, or property" by the federal and state governments, respectively, without due proces ...
of the Fourteenth Amendment did require notice or a hearing prior to the imposition of such punishment.


Background

James Ingraham was a 14-year-old eighth grade student at Charles R. Drew Junior High School in 1970. On October 6, 1970, Ingraham was accused of failing to promptly leave the stage of the school auditorium when asked to do so by a teacher. He was then taken to the school principal's office, where he stated that he was not guilty of the accusation against him. Willie J. Wright, Jr., the principal, ordered Ingraham to bend over so that Wright could spank Ingraham with a
spanking paddle A spanking paddle is an implement used to strike a person on the buttocks. The act of spanking a person with a paddle is known as "paddling". A paddling may be for punishment (normally of a student at school in the United States), for fun, or a ...
. When Ingraham declined to bend over and allow himself to be paddled, he was forcibly placed face-down on the top of a table. Lemmie Deliford, the assistant principal, held Ingraham's arms and Solomon Barnes, an assistant to the principal, held Ingraham's legs. While Ingraham was being restrained, Wright used a spanking paddle to hit Ingraham more than 20 times. The paddling was so severe that he suffered a
hematoma A hematoma, also spelled haematoma, or blood suffusion is a localized bleeding outside of blood vessels, due to either disease or trauma including injury or surgery and may involve blood continuing to seep from broken capillaries. A hematoma is ...
requiring medical attention. Physicians instructed Ingraham to rest at home for a total of eleven days. He and his parents sued the school, calling it "
cruel and unusual punishment Cruel and unusual punishment is a phrase in common law describing punishment that is considered unacceptable due to the suffering, pain, or humiliation it inflicts on the person subjected to the sanction. The precise definition varies by jurisdi ...
" and loss of
liberty Liberty is the state of being free within society from oppressive restrictions imposed by authority on one's way of life, behavior, or political views. The concept of liberty can vary depending on perspective and context. In the Constitutional ...
, but lost the initial trial. The
Florida Florida ( ; ) is a U.S. state, state in the Southeastern United States, Southeastern region of the United States. It borders the Gulf of Mexico to the west, Alabama to the northwest, Georgia (U.S. state), Georgia to the north, the Atlantic ...
state court held that Florida tort laws provided sufficient remedies to satisfy Ingraham's
due process Due process of law is application by the state of all legal rules and principles pertaining to a case so all legal rights that are owed to a person are respected. Due process balances the power of law of the land and protects the individual p ...
loss of
liberty Liberty is the state of being free within society from oppressive restrictions imposed by authority on one's way of life, behavior, or political views. The concept of liberty can vary depending on perspective and context. In the Constitutional ...
claims. The court also held that the U.S. Constitution's prohibition against cruel and unusual punishment does not apply to the corporal punishment of children in public schools, and that the constitution's due process clause does not require notice and a hearing prior to the imposition of corporal punishment in public schools.


Opinion of the Court

The Supreme Court declined to consider the plaintiffs' substantive due process claims in ''Ingraham v. Wright.'' Lower courts have adopted a variety of approaches to the substantive due process issue, none of which offer much protection for students who are subjected to corporal punishment at school. The Supreme Court has repeatedly denied ''
certiorari In law, ''certiorari'' is a court process to seek judicial review of a decision of a lower court or government agency. ''Certiorari'' comes from the name of a prerogative writ in England, issued by a superior court to direct that the recor ...
'' (judicial review) on the issue of whether school corporal punishment constitutes a substantive due process constitutional violation. As of 1994, Lemmie Deliford, one of the administrators involved, was still a proponent of corporal punishment in schools.


See also

* School corporal punishment in the United States


References


External links

* {{US8thAmendment United States Supreme Court cases 1977 in United States case law Spanking United States civil due process case law Cruel and Unusual Punishment Clause case law United States Supreme Court cases of the Burger Court Miami-Dade County Public Schools