## Facts

- James Ingraham, a 14-year-old public school student in Dade County, Florida, was disciplined by school officials using corporal punishment.
- Florida law and local school board rules authorized paddling for student misconduct, limiting punishment to that which was not “degrading or unduly severe.”
- Ingraham alleged he was accused of failing to leave an auditorium stage promptly, denied wrongdoing, and was ordered to submit to paddling.
- After refusing, he alleged staff forcibly restrained him on a table while he was struck repeatedly with a wooden paddle.
- He alleged serious injury (including a hematoma), medical treatment, and absence from school for more than a week.
- The students alleged a broader pattern of severe corporal punishment violating the Eighth and Fourteenth Amendments.
- The students sued school officials under 42 U.S.C. §§ 1981–1988 seeking damages and injunctive and declaratory relief.

## Issues

1. Whether the Eighth Amendment’s Cruel and Unusual Punishments Clause applies to disciplinary corporal punishment in public schools.
2. Whether the Fourteenth Amendment’s Due Process Clause requires notice and a hearing before public school officials impose corporal punishment.

## Decision

- The Supreme Court affirmed dismissal of the complaint in a 5–4 decision.
- The Court held the Eighth Amendment does not apply to corporal punishment in public schools.
- The Court held the Due Process Clause does not require pre-punishment notice and a hearing for school corporal punishment when state law authorizes the practice and traditional state remedies constrain excesses.
- The Court acknowledged that corporal punishment implicates a protected liberty interest in bodily integrity but concluded that post-deprivation remedies were constitutionally sufficient.

## Legal Principles

- The Eighth Amendment’s Cruel and Unusual Punishments Clause is directed to criminal punishment and does not govern ordinary public school disciplinary corporal punishment.
- Corporal punishment administered under color of state law implicates a Fourteenth Amendment liberty interest in personal security and freedom from bodily restraint and physical pain.
- Procedural due process does not require pre-deprivation notice and a hearing before corporal punishment in public schools when state law limits the practice and provides civil and criminal liability for excessive force.
- The availability of traditional post-deprivation state-law remedies may satisfy due process where requiring formal pre-punishment procedures would impose substantial administrative burdens on school discipline.

## Conclusion

The Court declined to constitutionalize routine regulation of school paddling, holding that the Eighth Amendment is limited to criminal punishment and that, although corporal punishment implicates a student’s liberty interest, due process generally does not require notice and a hearing before such discipline when state law authorizes it and provides meaningful remedies for abuse.


Ingraham v. Wright, 430 U.S. 651 (1977)