Ingraham v. Wright (1977)
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.
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.”
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.”
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