Ingraham v. Wright

430 U.S. 651 (1977)


Ps had been paddled by public school officials for alleged disciplinary violations while in junior high school without notice and opportunity for a prior hearing on disciplinary charges. The paddling of one student required medical treatment and incapacitated him for several days. Another was struck in the arm that deprived him of its full use for a week. A class action suit was brought against the school under 42. U.S.C. Section 1983-1988. The evidence, consisting mainly of the testimony of 16 students, suggests that the school regime was exceptionally harsh. Because he was slow to respond to his teacher's instructions, P was subjected to more than 20 licks with a paddle while being held over a table in the principal's office. The paddling was so severe that he suffered a hematoma requiring medical attention and keeping him out of school for several days. Another was paddled several times for minor infractions. On two occasions, he was struck on his arms, once depriving him of the full use of his arm for a week. The District Court made no findings on the credibility of the students' testimony. The court found no constitutional basis for relief. A panel of the Court of Appeals voted to reverse. The panel concluded that the punishment was so severe and oppressive as to violate the Eighth and Fourteenth Amendments and that the procedures outlined in Policy 5144 failed to satisfy the requirements of the Due Process Clause. Upon rehearing, the en banc court rejected these conclusions and affirmed the judgment of the District Court. The Eighth Amendment, in the court's view, was simply inapplicable to corporal punishment in public schools. The Supreme Court granted certiorari, limited to the questions of cruel and unusual punishment and procedural due process.