History and GovernmentSupreme CourtCases

Ingraham v. Wright (1977)


Case Summary

Two Florida students who were paddled in school brought suit in federal court arguing that the paddling was “cruel and unusual punishment” and that students should have a right to be heard before physical punishment is given. They lost in the trial court and at the Court of Appeals, and then appealed to the Supreme Court.

The Court's Decision

In a 5-4 decision, the Supreme Court decided that public school students could be paddled without first receiving a hearing.

Justice Lewis Powell wrote the majority opinion. He pointed out that the Eighth Amendment's ban on “cruel and unusual punishment” had always been applied to punishment of convicted criminals. The Court therefore did not apply the ban to non-criminal contexts, such as school discipline. Finally, Powell wrote that “In view of the low incidence of abuse, the openness of our schools, and the common law safeguards that already exist, the risk of error that may result in violation of a school child's substantive rights can only be regarded a minimal. Imposing additional administrative safeguards as a constitutional requirement might reduce that risk marginally, but would also entail a significant intrusion into an area of primary educational responsibility.”

Justice Byron White argued in dissent that the Eight Amendment does not contain the word “criminal,” so the Court should not impose that limitation. “The disciplinarian need only take a few minutes to give the student 'notice of the charge against him and, if he denies them, an explanation of the evidence the authorities have and an opportunity to present his side of the story.'” Justice White quoted an earlier case to support his opinion: “The Constitution requires, 'if anything, less than a fair-minded school principal would impose upon himself' in order to avoid injustice.”

More on the Case

Ingraham is one of a series of cases in which the Supreme Court has struggled to find the proper balance between the rights of individual students and the needs of school officials to maintain order to protect the rights of students as a group.

The quote in Justice White's dissent about a “fair-minded school principal” comes from another student-rights case, Goss v. Lopez, decided in 1975. In Goss v. Lopez, the Supreme Court held that a student must be given effective notice and at least an informal opportunity to tell his or her story before or soon after imposition of a suspension from school.

Ingraham was later relied on by both the majority and the dissent in yet another Supreme Court student-rights case, Vernonia School District 47J v. Acton, 1995. In that case, James Acton, then a seventh grader, was not allowed to play football because he and his parents refused to consent to mandatory random drug testing—a policy that had been unanimously endorsed by parents in a meeting called to address drug usage in the school. The majority found that drug testing did not violate the Constitution. In dissent, Justice Sandra Day O'Connor disputed the majority's reliance on Ingraham. In her view, Ingraham gave schools “substantial constitutional leeway in carrying out their traditional mission of responding to particularized wrongdoing.…By contrast, intrusive, blanket searches of school children, most of whom are innocent, for evidence of serious wrongdoing is not part of any traditional school function of which I am aware.”

Source: ©2005 Pearson Education, Inc., publishing as Pearson Prentice Hall. All rights reserved. Used by permission.

Information Please®, ©2005 Pearson Education, Inc. All Rights Reserved.

highlights

Special Books for the Kids You Love
Celebrate 20 years of sharing love to the moon and back with the anniversary edition of Guess How Much I Love You, one of the world’s best-loved picture books. Plus, search our Book Finder for more great book picks. Brought to you by Candlewick Press.

Vote Now for the Children's & Teen Choice Book Awards
Voting is open now through May 3 for the Children's and Teen Choice Book Awards — the only national book awards program where the winning author, illustrator, and books of the year are selected by young readers. Encourage your child to vote for his favorites today!

Top 10 Math & Science Apps for Your Whiz Kid
Looking for the best math and science apps for kids? Check out these cool apps for all ages, which will grow your child's love of the STEM subjects (science, technology, engineering, and math).

Registered for Kindergarten — Now What?
Wondering what to do now that you've signed your child up for kindergarten? Try our award-winning Kindergarten Readiness app! This easy-to-use checklist comes with games and activities to help your child build essential skills for kindergarten. Download the Kindergarten Readiness app today!

stay connected

Sign up for our free email newsletters and receive the latest advice and information on all things parenting.

Enter your email address to sign up or manage your account.

Facebook icon Facebook icon Follow Us on Pinterest

editor’s picks