Ingraham v. Wright
Encyclopedia
Ingraham v. Wright, , was a United States Supreme Court case that upheld the disciplinary corporal punishment
policy of Florida
's public schools by a 5–4 vote.
James Ingraham was a 14-year-old eighth grade student at Charles R. Drew Junior High School in 1970. On October 6, 1970, Ingraham was accused of failing to promptly leave "the stage of the school auditorium when asked to do so by a teacher". He was then taken to the school principal's office, where he stated that he was not guilty of the accusation against him. Willie J. Wright, Jr., the principal, ordered Ingraham to bend over so that Wright could beat Ingraham with a spanking paddle. When Ingraham declined to bend over and allow himself to be beaten, he was forcibly placed face-down on the top of a table. Lemmie Deliford, the assistant principal, held Ingraham's arms and Solomon Barnes, an assistant to the principal, held Ingraham's legs. While Ingraham was being restrained, Wright used a spanking paddle to hit Ingraham more than 20 times. The paddling was so severe that he suffered a hematoma
requiring medical attention. Physicians instructed Ingraham to rest at home for a total of eleven days. He and his parents sued the school, calling it "cruel and unusual punishment
" and loss of liberty
, but lost the case. The Court held that Florida
state tort laws provided sufficient remedies to satisfy Ingraham's due process
loss of liberty
claims. The Court also held that the U.S. Constitution's prohibition against cruel and unusual punishment does not apply to the corporal punishment of children in public schools, and that the constitution's due process clause does not require notice and a hearing prior to the imposition of corporal punishment in public schools.
The Supreme Court declined to consider the plaintiffs' substantive due process claims in Ingraham v. Wright. Lower courts have adopted a variety of approaches to the substantive due process issue, none of which offer much protection for students who are subjected to corporal punishment at school. The Supreme Court has repeatedly denied certiorari
(judicial review) on the issue of whether school corporal punishment constitutes a substantive due process constitutional violation.
Corporal punishment
Corporal punishment is a form of physical punishment that involves the deliberate infliction of pain as retribution for an offence, or for the purpose of disciplining or reforming a wrongdoer, or to deter attitudes or behaviour deemed unacceptable...
policy of Florida
Florida
Florida is a state in the southeastern United States, located on the nation's Atlantic and Gulf coasts. It is bordered to the west by the Gulf of Mexico, to the north by Alabama and Georgia and to the east by the Atlantic Ocean. With a population of 18,801,310 as measured by the 2010 census, it...
's public schools by a 5–4 vote.
James Ingraham was a 14-year-old eighth grade student at Charles R. Drew Junior High School in 1970. On October 6, 1970, Ingraham was accused of failing to promptly leave "the stage of the school auditorium when asked to do so by a teacher". He was then taken to the school principal's office, where he stated that he was not guilty of the accusation against him. Willie J. Wright, Jr., the principal, ordered Ingraham to bend over so that Wright could beat Ingraham with a spanking paddle. When Ingraham declined to bend over and allow himself to be beaten, he was forcibly placed face-down on the top of a table. Lemmie Deliford, the assistant principal, held Ingraham's arms and Solomon Barnes, an assistant to the principal, held Ingraham's legs. While Ingraham was being restrained, Wright used a spanking paddle to hit Ingraham more than 20 times. The paddling was so severe that he suffered a hematoma
Hematoma
A hematoma, or haematoma, is a localized collection of blood outside the blood vessels, usually in liquid form within the tissue. This distinguishes it from an ecchymosis, which is the spread of blood under the skin in a thin layer, commonly called a bruise...
requiring medical attention. Physicians instructed Ingraham to rest at home for a total of eleven days. He and his parents sued the school, calling it "cruel and unusual punishment
Cruel and unusual punishment
Cruel and unusual punishment is a phrase describing criminal punishment which is considered unacceptable due to the suffering or humiliation it inflicts on the condemned person...
" and loss of liberty
Liberty
Liberty is a moral and political principle, or Right, that identifies the condition in which human beings are able to govern themselves, to behave according to their own free will, and take responsibility for their actions...
, but lost the case. The Court held that Florida
Florida
Florida is a state in the southeastern United States, located on the nation's Atlantic and Gulf coasts. It is bordered to the west by the Gulf of Mexico, to the north by Alabama and Georgia and to the east by the Atlantic Ocean. With a population of 18,801,310 as measured by the 2010 census, it...
state tort laws provided sufficient remedies to satisfy Ingraham's due process
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
loss of liberty
Liberty
Liberty is a moral and political principle, or Right, that identifies the condition in which human beings are able to govern themselves, to behave according to their own free will, and take responsibility for their actions...
claims. The Court also held that the U.S. Constitution's prohibition against cruel and unusual punishment does not apply to the corporal punishment of children in public schools, and that the constitution's due process clause does not require notice and a hearing prior to the imposition of corporal punishment in public schools.
The Supreme Court declined to consider the plaintiffs' substantive due process claims in Ingraham v. Wright. Lower courts have adopted a variety of approaches to the substantive due process issue, none of which offer much protection for students who are subjected to corporal punishment at school. The Supreme Court has repeatedly denied certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
(judicial review) on the issue of whether school corporal punishment constitutes a substantive due process constitutional violation.