Law School Case Brief
Ingraham v. Wright - 430 U.S. 651, 97 S. Ct. 1401 (1977)
The primary purpose of the Cruel and Unusual Punishments Clause has always been considered, and properly so, to be directed at the method or kind of punishment imposed for the violation of criminal statutes. When public school teachers or administrators impose disciplinary corporal punishment, the Eight Amendment is inapplicable
Two students in a public high school in Florida instituted an action pursuant to 42 U.SC.S. §§1981-1988 in the United States District Court for the Southern District of Florida, against certain school officials, alleging a violation of their Eighth and Fourteenth Amendment rights based on disciplinary paddling incidents. According to the evidence presented, the students were subjected to disciplinary paddling without prior notice and a hearing. The paddlings were so severe as to keep one of the students out of school for 11 days and to deprive the other student of the full use of his arm for a week. The students argued that the use of corporal punishment was cruel and unusual, and thus violated the Eighth Amendment. At the time of the incident, the Florida statute in effect authorized corporal punishment after the teacher had consulted with the principal or teacher in charge of the school, specifying that the punishment was not to be "degrading or unduly severe." The district court dismissed the complaint, holding that there was no constitutional basis for relief. The Court of Appeals affirmed. The students appealed.
Did the disciplinary paddling of public school students constitute cruel and unusual punishment in violation of the Eighth Amendment?
Affirming, the Supreme Court of the United States held that the disciplinary paddling of public school students did not constitute cruel and unusual punishment in violation of the Eighth Amendment. The Court explained that because the Eighth Amendment was designed to protect those convicted of crime, it did not apply to disciplinary corporal punishment of public school children. According to the Court, the extension of the cruel and unusual punishment clause to ban the paddling of school children was not justified, because public schools were open to public scrutiny and were supervised by the community. Furthermore, teachers and administrators were subject to the legal constraints of the common law whereby any punishment exceeding that which was reasonably necessary for the proper education and discipline of the child could result in both civil and criminal liability under state law. As long as the schools were open to public scrutiny, the Court saw no reason to believe that the common-law constraints would not effectively remedy and deter excess punishment. Furthermore, the Court noted that the students were not entitled to prior notice and an opportunity to be heard pursuant to the Due Process Clause of U.S. Const. amend. XIV.
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