Ingraham v. Wright

Supreme Court of the United States · 1977 · Administrative Law

Administrative LawConstitutional LawPublic School DisciplineEighth AmendmentProcedural Due Processcorporal punishmentpublic schoolsEighth Amendment

Facts

Dade County schools used corporal punishment under Florida law and local school board policy authorizing paddling on the buttocks with a wooden paddle as a disciplinary measure. Petitioners introduced evidence that at Drew Junior High School the practice could be harsh; Ingraham received more than 20 licks while held over a table and suffered a hematoma, and Andrews was paddled several times, including blows to his arms. The evidence also showed that, contrary to statutory and regulatory requirements, teachers often paddled students without first consulting the principal. The District Court assumed the students' testimony was credible but held that no constitutional violation had been shown.

Issue

Does paddling students in public schools constitute cruel and unusual punishment under the Eighth Amendment? If corporal punishment is constitutionally permissible, does the Fourteenth Amendment's Due Process Clause require notice and an opportunity to be heard before school officials administer it?

Rule

The Eighth Amendment's prohibition on cruel and unusual punishments is limited to punishments imposed in the criminal process and does not apply to disciplinary corporal punishment in public schools. Although school corporal punishment that deliberately restrains a child and inflicts appreciable physical pain implicates a protected liberty interest, due process is satisfied without prior notice and hearing when the practice is traditionally authorized by common law and meaningful civil and criminal remedies exist for excessive punishment.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

At a public middle school in Columbus, Ohio, assistant principal Dana Mercer orders student Leo Martin to bend over a chair and strikes him six times with a wooden paddle for repeatedly shouting in class. Leo sues in federal court, alleging the paddling was cruel and unusual punishment under the Eighth Amendment.

How should the court rule on Leo's Eighth Amendment claim?

Explanation. The majority held that the Eighth Amendment's Cruel and Unusual Punishments Clause applies to punishments associated with the criminal process, not to corporal punishment imposed in public schools as discipline. The relevant federal constitutional inquiry for school paddling is under the Due Process Clause, not the Eighth Amendment.