Citation: Ingraham v. Wright 430 U.S. 651 (1977)
Topic: Corporal Punishment in Public Schools
Issue:
The case of Ingraham v. Wright presents the argument concerning the use of corporal punishment (CP) in the public school system. The first question involves whether the use of student paddling to maintain discipline constitutes cruel and unusual punishment and if it violates the rights of the Eighth Amendment. Additionally, in the extent that paddling is permissible under the constitution, does the Due Process Clause of the Fourteenth Amendment require that prior notice and an opportunity to be heard need to be given to the student receiving punishment.
Facts:
The case of Ingraham v. Wright began in October 1970 when James Ingraham and Roosevelt Andrews, Junior High students at Charles R. Drew Junior High in Dade County (Miami), Florida, filed a complaint against the school. The complaint contained two counts for deprivation of constitutional rights for damages suffered by both students after a paddling at school by the school principal Willie J. Wright. A third count was a class action suit filed on behalf of all students in Dade County schools for declarative and injunctive relief. In essence, the third count was for the admission of a wrong doing, and to ask the courts for further judgment on the issue of corporal punishment use in schools.
In the early 1970’s Florida law permitted CP in schools (spanking or paddling), but with certain restraints. Teachers were to get permission from the principal before paddling and it was to be limited to one to five “licks” on the student’s buttocks. Teachers, however, paddled without permission and many times gave more than five spankings.
In October 1970, it was alleged that Ingraham was slow to respond to a teacher’s instructions. He was sent to the principal’s office, held over a table by his arms and legs, and received 20 licks with a paddle. His paddling resulted in the formation of a hematoma (a pool of blood under the skin on his backside), and several days of missed school. In the same month, Andrews was paddled on several occasions for breaking minor school rules. Andrews received multiple paddlings on his arms and lost the use of one arm for several days after. Another student was reported to have received 50 licks for making an obscene phone call.
Both Ingraham and Roosevelt filed a lawsuit against the principals of the Junior High and the Dade County School District. Lawyers said that the schools violated the students’ Eighth and Fourteenth Amendment rights by using cruel and unusual punishment and not allowing a hearing before the paddling, respectively. The students were hoping to recover their damages and prevent future use of corporal punishment in the school system.
Findings and Rationale:
The trial court dismissed the case and the court of appeals agreed. From there the case was sent onto the U.S. Supreme Court. In a 5-4 decision, the Court ruled in favor of the school. Under the Eighth Amendment which states, “Excessive bail shall not be required, nor excessive fines imposed, nor cruel and unusual punishments inflicted,” the court stated that bail, fines, and punishment are part of the criminal system. Since schools are not part of that system, they do not have to obey the eighth amendment.
The court also rejected the argument under the Fourteenth Amendment that schools should give students a hearing before administering the punishment. Laws in Florida allowed students injured by corporal punishment to sue officials for the recovery of damages. The court stated that forcing schools to hold a hearing for every case of corporal punishment would be time consuming and too costly.
Since the United States Constitution does not explicitly grant the Federal government power regarding education, it is therefore reserved to the states. The court also recognized that schools are separate from the criminal system, and therefore corporal punishment in schools could not be challenged under the cruel and unusual punishment clause of the Eighth Amendment. Finally, under the Fourteenth Amendment, the power also resided back to the states to decide the Due Process of any action taken against the schools.
Implications:
The implications of this case on today’s educators brings about the issue of corporal punishment and whether it should or should not be used as a way to discipline students. Immediately after this case went to the Supreme Court, two states passed laws making it illegal to use corporal punishment (paddling) in school. It was not until the early 1990’s that 21 more states passed similar laws. Today, in 2011, 20 states still have laws that allow CP in schools.
A big debate looms in the school system today over positive versus negative reinforcement. Which is more effective? Does the same type of reinforcement work for all children? While we may not have all the answers, this case set the precedent to abolish a practice established in a very different time, and under very different social, political, and educational regimes.
View my Prezi Corporal Punishment in Schools - Does it Still Exist? (a presentation on the topic).
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