Patrick Stieve

Kristin Whitley

430 U.S. 651

Ingraham v. Wright

CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT

No. 75-6527 Argued: November 2, 1976 --- Decided: April 19, 1977

Background:

Students in a Dade County, Florida junior high school filed suit in Federal District Court for “damages and injunctive and declaratory relief” against officials of the school. The complaint was that the petitioners’, along with other students’ constitutional rights had been violated by disciplinary corporal punishment. A Florida statute gave teachers authorization to impose corporal punishment upon students after they consulted with the principal or teacher in charge of the school and specifying that the punishment could not be “degrading or unduly severe”. A School Board regulation stated specific directions and limitations that the punishment given to an unruly student was to be on the “student’s buttocks with a wooden paddle”. Evidence showed that the paddling of the petitioners was exceptionally harsh.

Decision and Rationale:

The District Court found no basis for constitutional relief and granted the defendants’ motion to dismiss the complaint. The Court of Appeals affirmed. They held that the Cruel and Unusual Punishments clause of the Eighth Amendment doesn’t apply to disciplinary corporal punishment in schools; the Eighth Amendment was designed to protect convicted criminals. They also held that the Due Process Clause of the Fourteenth Amendment does not require notice and hearing before imposition of corporal punishment because it is authorized and limited by common law. However, it does protect students from unjustified corporal punishment. It states that “the teacher and principal must exercise prudent and restraint when they decide corporal punishment is necessary for disciplinary purposes”. However, the Due Process Clause also says that if punishment was later found to be excessive, school officials may be held liable for damages or subject to criminal penalties.

Impact on Teaching:

The decision in this case grants the continuance of corporal punishment, as long as local laws allow it. Individual teachers no longer are the initiators of paddling students; this lovely job has been passed on to administrators. What has been pointed out though with this case is liability. Schools must keep corporal punishments inside the scope of reasonable. If there is any doubt, the school system could end up being sued. In all reality this is just another issue to give more power to students in public school, thus making our job slightly more difficult when disciplining students.

Test Question:

T/F?

Ingraham v. White upheld that schools could not enforce corporal punishment ever again.

FALSE