Ingraham v. Wright: Supreme Court Case, Arguments, Impact

Ingraham v. Wright (1977) asked the U.S. Supreme Court to decide if corporal punishment in public schools violates the Eighth Amendment of the U.S. Constitution. The Court ruled that physical punishment does not qualify as "cruel and unusual punishment" under the Eighth Amendment.

Facts of the Case

On October 6, 1970, James Ingraham and a number of other students at Drew Junior High School allegedly left the school auditorium too slowly. The students were escorted to Principal Willie J. Wright’s office where he administered corporal punishment in the form of paddling. Ingraham refused to be paddled. Principal Wright called two assistant principals into his office to hold Ingraham down while he administered 20 blows. After the incident, Ingraham’s mother brought him to a hospital where he was diagnosed with a hematoma. Ingraham could not sit comfortably for more than two weeks, he later testified. 

Roosevelt Andrews spent only a year at Drew Junior High School but received physical punishment ten times in the form of paddling. In one instance, Andrews and fourteen other boys were paddled by Assistant Principal Solomon Barnes in a school restroom. Andrews had been marked tardy by a teacher, even though he insisted he was not. Andrews' father spoke to school administrators about the incident but was told corporal punishment was part of the school's policy. Less than two weeks later, Assistant Principal Barnes attempted to administer corporal punishment again on Andrews. Andrews resisted and Barnes struck him on the arm, back and across his neck. Andrews claimed that, on at least two separate occasions, he was hit on the arms hard enough that he could not fully use one of arms for a full week.

Ingraham and Andrews filed a complaint on January 7, 1971. The complaint alleged that the school violated their Eighth Amendment protections against cruel and unusual punishment. They sought damages for relief. They also filed a class action suit on behalf of all of the students in the Dade County school district.

Constitutional Question

The Eighth Amendment reads, “excessive bail shall not be required, nor excessive fines imposed, nor cruel and unusual punishments inflicted.” Does physical punishment in schools violate the Eighth Amendment's prohibition of cruel and unusual punishment? If so, are students entitled to a hearing prior to receiving corporal punishment?

Arguments

Attorneys representing Ingraham and Andrews argued that students are protected under the Constitution on and off school property. Therefore, the Eighth Amendment protects them from physical punishment at the hands of school officials. Corporal punishment administered at Drew Junior High School was “arbitrary, capricious and wantonly and freakishly imposed,” attorneys argued in their brief. It violated the very concept of human dignity embodied in the Eighth Amendment.

Attorneys on behalf of the school district and state argued that the Eighth Amendment applies only to criminal proceedings. Corporal punishment has always been an approved method in educational settings, understood in common law and by state statutes. If the court were to step in and find that corporal punishment violates the Eighth Amendment, it would remove the possibility of state remedies. It would also open the door to numerous legal cases alleging “severe” or “disproportionate” punishment in schools, the attorneys argued.

Majority Opinion

Justice Lewis Powell delivered the 5-4 decision. Corporal punishment does not violate the Eighth or Fourteenth Amendments, the Court found.

Justices first analyzed the legitimacy of the Eighth Amendment claims. The Court noted that historically, the Eighth Amendment was designed to protect prisoners who had already been deprived of other liberties. “The openness of the public school and its supervision by the community afford significant safeguards against the kinds of abuses from which the Eighth Amendment protects the prisoner,” Justice Powell wrote. The distinction between a prisoner and a student provides sufficient cause to rule that the Eighth Amendment does not apply to students at a public school. Students cannot allege cruel and unusual punishment when corporal punishment is applied on school grounds, the Court found.

Next, the Court turned to the Fourteenth Amendment Due Process claims. Corporal punishment has a "limited" effect on a student's constitutional liberty, the Court noted. Historically, corporal punishment has been left to the states to legislate, the majority found. There is a longstanding common law tradition that requires this type of punishment to be reasonable but not “excessive.” If corporal punishment becomes "excessive" students may seek damages or criminal charges in court. Courts use a number of factors to decide if punishment has become "excessive" including the age of the child, the child’s physical attributes, the severity of the punishment, and the availability of alternatives. After reviewing the legal standards for evaluating corporal punishment, the Court concluded that the common law safeguards were sufficient.

Justice Powell wrote:

“Elimination or curtailment of corporal punishment would be welcomed by many as a societal advance. But when such a policy choice may result from this Court's determination of an asserted right to due process, rather than from the normal processes of community debate and legislative action, the societal costs cannot be dismissed as insubstantial.”

Dissenting Opinion

Justice Byron White dissented, joined by Justice William J. Brennan, Justice Thurgood Marshall, and Justice John Paul Stevens. Justice White argued that the Eighth Amendment could be applied to students. Nowhere in the actual text of the Eighth Amendment is the word “criminal,” he pointed out. In some circumstances, Justice White argued, it is possible for corporal punishment to be so severe that it warrants Eighth Amendment protections. Justice White also took issue with the majority’s view that students are not entitled to a hearing before being subjected to corporal punishment. 

Impact

Ingraham remains the definitive case on corporal punishment, but the ruling did not stop states from legislating against physical punishment in schools. In 2019, nearly 40 years after Ingraham v. Wright, only 19 states still allowed corporal punishment in schools. In some states, district-wide bans have effectively eliminated corporal punishment, even though the state still allows it to be used. The last remaining North Carolina school district, for example, banned corporal punishment in 2018, effectively ending the practice in the state without removing the state law from the books.

Ingraham v. Wright has been cited in other Supreme Court decisions regarding the rights of students. In Vernonia School District 47J v. Acton (1995), a student refused to be drug tested in order to participate in school-sanctioned sports. The student alleged that the policy violated his constitutional rights. The majority found that the student’s rights were not violated by the mandatory drug test. Both the majority and dissent relied on Ingraham v. Wright.

Sources

• Ingraham v. Wright, 430 U.S. 651 (1977).
• Vernonia School Dist. 47J v. Acton, 515 U.S. 646 (1995).
• Park, Ryan. “Opinion | The Supreme Court Didn't Ban Corporal Punishment. Local Democracy Did.” The Washington Post, WP Company, 11 Apr. 2019, www.washingtonpost.com/opinions/the-supreme-court-didnt-ban-corporal-punishment-local-democracy-did/2019/04/11/b059e8fa-5554-11e9-814f-e2f46684196e_story.html.
• Caron, Christina. “In 19 States, It's Still Legal to Spank Children in Public Schools.” The New York Times, The New York Times, 13 Dec. 2018, www.nytimes.com/2018/12/13/us/corporal-punishment-school-tennessee.html.
• Schuppe, Jon. “Georgia School Paddling Case Highlights Continued Use of Corporal Punishment.” NBCNews.com, NBCUniversal News Group, 16 Apr. 2016, www.nbcnews.com/news/us-news/georgia-school-paddling-case-highlights-continued-use-corporal-punishment-n556566.