Summary of Ingraham v.

Wright
Citation: 430 U.S. 651 (1977)
Relevant Facts: James Ingraham was a junior high student in a Florida public school. After failing to
respond quickly to a teachers instructions, Ingraham was brought to Principal Willie Wrights office
where he refused to admit the infraction. Ingraham was then subjected to corporal punishment by
Principal Wright, with the help of the Assistant Principal and his personal assistant. According to the
record, Ingrahams spanking was particularly harsh as he was subjected to twenty separate strokes
from the wooden paddle. Ingrahams doctors ordered him to remain out of school to recover from
injuries sustained during his paddling. Ingraham and another student brought suit alleging that Florida
law allowing corporal punishment violated the Eighth Amendment, violated their due process rights,
and sought damages in addition to declaratory and injunctive relief. The district Court granted
Wrights motion to dismiss and the Court of Appeals affirmed.
Issue: Does the Eighth Amendment bar corporal punishment in public schools? Does due process
require notice to parents before corporal punishment is imposed?
Holding: No, the Eighth Amendment has no application to corporal punishment in public schools. No,
notice is not required before administering punishing as the Florida statutory scheme contains
adequate safeguards to prevent wrongful punishment, and affords adequate remedies in the event a
student is deprived of his rights.
Reasoning: Justice Powell delivered the opinion of the Court. First, the majority noted that the Eighth
Amendment historically applied to those convicted of crimes rather than to the disciplining of school
children. Justice Powell explained that there was no basis for extending the Eighth Amendment
beyond that historical context, particularly as applied to schools that are already carefully monitored
by local communities. Furthermore, aggrieved students and parents can seek criminal and civil
remedies in the event punishments exceed what is necessary to enforce rules and impose discipline
within the school environment. Next, the Court turned to the Due Process issue, explaining that both
physical restraint and infliction of pain are within the historical meaning of liberty interest protected by
guarantees of due process of law. Children obviously have a strong and legitimate interest in avoiding
unwarranted punishments or being unnecessarily deprived of their liberty. However, the Court here
concluded Florida law already contained adequate protections, with teachers and principals alike
required to exercise prudence in applying punishments, subject to the watchful eye of the community
and the possibility of subsequent civil or criminal liability for wrongful behavior. The Court saw no
need to add pre-punishment notifications, as school discipline has always been handled without the
need for prior notification or hearings. Finally, the Court explained that imposing additional
requirements on schools seeking to impose punishments would intrude state authority to regulate
schools. Justice Powell pointed out that additional safeguards may well require schools to abandon
certain modes of punishment, and any small benefit from adding constitutional remedies to already
existing tort and criminal remedies were small compared to the important interests of schools
protecting their educational environments.
Dissent: Justice White dissented, joined by Justices Brennan, Marshall, and Stevens. Justice White
argued that the Eighth Amendments prohibitions extended to all cruel and unusual punishments,
such that a punishment inflicted on a criminal defendant that violates the Eighth Amendment must
also be prohibited for disciplining school children. The dissenters argued that it was of little
consequence that potential violations were relatively rare, or that post-punishment remedies existed,
as any violations should be afforded judicial protection and availability of other remedies is not
dispositive of the Constitutional question. Similarly, the dissenters disagreed with the majority
regarding due process analysis. They concluded that post-punishment remedies did not remove the
danger of erroneous deprivation of rights, in particular where physical punishments were inflicted. The
dissenters found it strange that students were entitled to a due process hearing prior to suspension
under the Courts precedents, but not in the event corporal punishment was imposed. Justice Stevens
filed a separate dissenting opinion. He argued that while some constitutional violations can be
remedy by subsequent suits to recover money damages, others necessitate adequate safeguards to
prevent violations before they occur as damages following post-violation reviews may be inadequate
to make the afflicted individual whole again.
Conclusion: The Court concluded that the Eighth Amendment did not bar corporal punishment in
public schools, reasoning that adequate safeguards were in place to prevent erroneous application,
and in the event of mistakes, students were afforded civil and criminal remedies sufficient to cure the
violation of their rights.