Ingraham v. Wright

525 F.2d 909 (1977)

by

Heather Wilson

 

Facts of the Case:

James Ingraham and Roosevelt Andrews were enrolled in the Charles R. Drew Junior High School in Dade County Florida. Ingraham and Andrews stated that they had been paddled in school an excessive amount of times with an excessive force. They claimed that the act of paddling was in violation to their rights under the Eighth Amendment because the paddling was excessive and also in violation of the Fourteenth Amendment because the authorities did not give them an opportunity to be heard before the paddling took place. The defendants in this case were Principal Willie J Wright, assistant Principals Lemmie Deliford and Solomon Barnes, and Superintendent Edward L Whigham. When the case was brought to the United States District Court for the Southern District of Florida, the district court dismissed all three counts before even hearing the evidence. The case was brought to a panel of the court of appeals which voted to reverse the decision of the district court on the grounds that the punishment was “severe and oppressive” and violated the Eighth and Fourteenth Amendments. Upon rehearing, the en banc court rejected the decision made the court of appeals and affirmed the judgment of the district court. Ingraham then appealed to the Supreme Court.

Court Decision:

The Supreme Court’s decision in Ingraham v. Wright affirmed the decision made the district court and the en banc court of appeals. The Supreme Court ruled that the public schools were allowed to paddle students without first giving a hearing.

Basis for Decision:

The decision of the Supreme Court was made based on the fact that “cruel and unusual punishment” under the Eighth Amendment only applies to those convicted of a crime and not actions used for discipline in a public school. The Court did not see any need to expand the Eighth Amendment to include disciplinary actions taken by public schools to punish students. Also it was held that because the punishment inflicted upon the students was physical punishment it was not covered under due process in the Fourteenth Amendment. In making this decision the Supreme Court looked at cases such as Powell v. Texas, United States v. Barnett, and Greene v. McElroy. These cases were looked upon because they shared a similar ruling is letting tradition stand instead of adjusting the amendments to fit the case.