Ingraham v Wright Case Brief PDF

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Ingraham v. Wright, 430 U.S. 651 (1977) Characters: Petitioners – James Ingraham and Roosevelt Andrews. Students in a Dade County, Florida, junior high school, Ingraham in eighth grade and Roosevelt in ninth. Suing the respondents on the terms of paddling students in order to maintain school discipline constitutes as cruel and unusual punishment (eighth amendment). Respondents – Willie J. Wright (Principal), Lemmie Deliford (Assistant Principal), Solomon Barnes (An assistant to the principal), and Edward L. Whigham (Superintendent of the Dade County School System) Behavior: Ingraham appeared slow in response to his teacher’s instructions and was subjected to more than twenty “licks” with the paddle while being held over a table in the principal’s office. Due to such force, he suffered a hematoma and received medical attention for his injuries. On two occasions while Andrews was subjected to being paddled, he was struck on his arm, once depriving him of the full use of his arm for a week. Principal Wright would call upon Assistant Principal Deliford and Barnes to hold the petitioning students (Ingraham and Andrews) in a prone position while Wright administered blows with a paddle, causing the development of medical expenses. The Law(s) Involved: The students claimed that the use of corporal punishment at school constituted cruel and unusual punishment in violation of the United States Constitutional Amendment VIII and that they were entitled to prior notice and an opportunity to be heard prior to the administration of the punishment under the Due Process Clause of the United States Constitution Amendment XIV. The Specific Constitutional Provision Involved: Eighth Amendment and the Due Process Clause The Arguments: Respondent school officials argued that the court of appeals correctly ruled that paddling was not an activity which was substantial enough, on a constitutional level, to justify a school’s time and effort or the court’s interference into a school’s internal matters. The Eighth Amendment did not apply to corporal punishment in public schools. Paddling of disobedient children had long been an accepted method of promoting good behavior and instilling notions of responsibility and modesty into the mischievous heads of school children. Petitioner students argued that corporal punishment was cruel, unusual, and wrong. The students also argued that the prohibition against cruel and unusual punishment should have been extended to ban the paddling of schoolchildren because the Framers of the Eighth Amendment could not have envisioned the present system of public and compulsory education, with its opportunities for noncriminal punishments. Otherwise, courts would provide greater protection to criminals than to school children. It would be abnormal if schoolchildren could be beaten without constitutional reparation, while hardened criminals suffering the same beatings at the hands of their jailers have a valid claim under the Eighth Amendment. The Constitutional Issue: 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. The Legal History: Petitioners, two junior high students, through their parents, filed an action against respondent school officials in the United States District Court for the Southern District of Florida, alleging violation of their rights pursuant to the United States Constitutional Amendment VIII and U.S. Constitutional Amendment XIV based on unneccessary disciplinary paddling incidents. Counts one and two were individual actions for compensatory and punitive damages brought under 42 U.S. Code § 1981 issuing a statement of equal rights, “Make and Enforce Contracts”, and protection against impairment with jurisdiction claimed under 28 U.S. Code § 1331 issuing the district courts to have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States; and 28 U.S. Code § 1343 enduring the district court having original jurisdiction of any civil action authorized by law to be commenced by a person to recover damages. Count three was a class action brought by the students as representatives of the class of students of the Dade County school system who were subject to the corporal punishment policies issued by respondent members of the Dade County school system who were subject to the corporal punishment policies issued by respondent members of the Dade County School Board.

The District Court dismissed the complaint, holding that there was no constitutional basis for relief. A panel of the United States Court of Appeals for the Fifth Circuit originally voted to reverse, but the Court of Appeals vacated its prior judgement and affirmed the district court’s judgment. The United States Supreme Court granted the students’ petition for certiorari. Unique Background or Contextual Factors: The children compared themselves to those who commit crimes and who have protection under the Eighth Amendment, however, the judges and respondents do not believe that paddling should be considered as “cruel and unusual.” The Court’s (Majority) Holding and Dispensation: The Supreme Court held that the banning against cruel and unusual punishment in the Eighth Amendment protected those convicted of crimes and did not apply to the paddling of children as a means of sustaining discipline in public schools. The cruel and unusual punishment clause restricted the criminal process by limiting the kinds of punishment that could be imposed on those convicted of crimes, by excluding punishment grossly inconsistent to the severity of the crime, and by imposing functional limits on what could be made criminal and punished. Where school authorities, acting under color of state law, intentionally decided to punish a child for misconduct by restraining the child and imposing significant physical pain, the Court held that the Fourteenth Amendment liberty interests were implicated. However, the purpose for corporal punishment was to correct a child’s behavior without interrupting his education. The court reasoned, teachers and school authorities were unlikely to inflict corporal punishment that was unnecessary or unreasonable when a possible consequence of doing so was the institution of civil or criminal proceedings against them. Finally, the Court found that the additional defense of a hearing to the students was outweighed by the cost. The Court concluded that the Due Process Clause did not require notice and a hearing prior to the imposition of corporal punishment in the public schools, as the practice was authorized and limited by the common law. The Court’s Expressed Reasoning (The Majority Opinion): In this case, the Court did not decide whether or under what circumstances corporal punishment of a public-school child could give rise to an independent federal cause of action to justify substantive rights under the Due Process Clause. If the Eighth Amendment did not obtain sensible spanking in public schools, it was because these spanking were not considered “cruel and unusual.” Spanking in the Florida public schools was punishment within the meaning of the Eighth Amendment, and disagreed with the majority’s argument that schoolchildren did not need Eighth Amendment protection because corporal punishment was less subject to abuse in the public schools than it was in the prison system. Further, the majority opinion criticized the majority for relying on the fact that a person may have a statelaw cause of action against a public official. Concurring and Dissenting Opinions: Justice White, with whom Justices Brennan, Marshall, and Stevens join, dissenting. The Court holds that corporal punishment in public schools, no matter how severe, can never be subject of the protections afforded by the Eighth Amendment. It also holds that students in the public-school systems are not constitutionally entitled to a hearing of any sort before beatings can be inflicted on them. Because Justice White believes that these holdings are inconsistent with the prior decisions of the Court and are contrary to a reasoned analysis of the constitutional provisions involved. Personal Notes:...