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A Legal Analysis of Ingraham v. Wright

By Virginia Lee

From Corporal Punishment in American Education,  ed. Hyman & Wise

Temple University Press, Philadelphia, 1979



Fourteen-year-old James Ingraham was an eighth grader attending Drew Junior High School in Dade County, Florida. On October 6, 1970, a number of students, including James, were slow in leaving the stage of the school auditorium when asked to do so by a teacher. The school principal, Willie J. Wright, Jr., took James and the other students to his office to be paddled. When James protested, claiming his innocence, Lemmie Deliford, the assistant principal, and Solomon Barnes, an assistant to the principal, were called in. Q. Do you remember if he told you how many times he was going to beat you?

A. Started off with five, then he went up to twenty. ...

Q. How did he paddle you, if you resisted it?

A. They took off their coats when they come in....

Q. Who were "they"?

A. Mr. Deliford, Mr. Barnes and Mr. Wright.

Q. They took off their coats?...

A. Yes, and their watches.

Q. Then what did they do?

A. Told me to take the stuff off my pockets and take off my coat. ...

Q. Then what did they tell you to do?

A. "Stoop over and get your licks." ...

Q. Did you do that when they told you to do it?

A. No.

Q. What did you do?...

A. I stand up.

Q. Then what happened?

A. They grabbed me; took me across the table.

Q. Who were "they?"

A. Mr. Deliford, Mr. Barnes and Mr. Wright. ... Q. You say Mr. Barnes and Mr. Deliford did what?

A. Put me across the table.

Q. Show me how they did that. ...

Mr. Feinberg. Let the record reflect the witness is lying prone, face down, across the...table, with his feet off the floor. ...

Q. Who held you there?

A. Mr. Barnes and Mr. Deliford

Q. Who held what?

A. Mr. Barnes held my legs and Mr. Deliford held my arms.

Q. Who paddled you?

A. Mr. Wright.

Q. You said he was going to give you how many licks?

A. Twenty.

Q. How many did he give you?

A. More than twenty. ...

Q. Did it hurt? ...

A. Yes, it hurt.

Q. Did you cry? A. Yeah. ...

Q. What happened after he finished paddling you?...

A. He told me to go wait.

Q. Did Mr. Wright say anything to you after you were paddled?

A. To put on my clothes. ...

Q. ... Then what did he say to you?...

A. "Wait outside of the office." ...

Q. Did you have to open the door to get out of there?

A. He opened the door and told me if I move -- I said I was going home -- he said if I move he was going to bust me on the side of my head.

James went home anyway and examined his injuries. According to James, his backside was "black and purple and it was tight and hot." He was "ashamed" to show the injuries to his mother, and when he did she became hysterical and started "screaming and hollering." James's mother took him to a local hospital where the examining doctor diagnosed the cause of James's pain to be a "hematoma." "The area of pain was tender and large in size, and... the temperature of the skin area of the hematoma was above normal which is a sign of inflammation often associated with hematoma."

The doctor prescribed pain pills, a laxative, sleep pills and ice packs, and advised James to stay at home for at least a week. A different doctor examined James on October 9 when he returned to the hospital for treatment, and again on October 14. This doctor found "a hematoma approximately six inches in diameter which was swollen, tender, and purplish in color. Additionally, there was serousness or fluid oozing from the hematoma." On October 14, eight days after the paddling, this doctor indicater that James should rest at home " 'for the next 72 hours.' James testified that it was painful even to lie on his back in the days following the paddling, and that he could not sit comfortably for about three weeks."

Roosevelt Andrews was another student attending Drew Junior High School. During his one year there he was paddled approximately ten times. Roosevelt was beaten by Lemmie Deliford several times. Solomon Barnes, who nearly always carried a paddle with him, paddled Roosevelt four times within a twenty-day period.

On one occasion, Roosevelt was headed for his physical education class.

Q. Who stopped you?

A. Mr. Dean. ...

Q. What did he say to you; do you remember?

A. He said I was late.

Q. What did you say?

A. "I got two more minutes, and I can make it"

Q. What did he do?

A. He said I couldn't make it, so he took me to Mr. Barnes.

Q. Where was Mr. Barnes at this time?

A. He was walking to the bathroom at the time.

Q. Did he have a paddle with him?

A. Yeah. ...

Q. You got to the bathroom; is that right?

A. Yeah.

Q. Then what happened?

A. When I got there there was lots of children, lots of boys.

Q. How many boys were there?

A. Maybe fourteen, fifteen.

Q. You say "there." Where do you mean by "there"?

A. In the bathroom, inside.

Q. What were they doing in there?

A. Standing up when I got in there.

Q. Where was Mr. Barnes?

A. Standing at the door. ...

Q. Then what happened?

A. He started beating them boys at first.

Q. Did he say anything to them before he beat them?

A. "Get over here," and that's all.

Q. How did he make them stand when he beat them?

A. I got to show that too?

Q. Sure. Show me how he made them stand when he beat them. Stand up and show me. ...

A. Well, you know how the squares are in the bathroom, the lines on the floor, he tell me to get ... to a certain line and then bend over to the urinate thing.

Q. On the what?

A. He tell you to stand like the third line and like this is the bath urinate.

Q. That is what?

A. Urinate place.

Q. Then what did he say?

A. He says--like the line here going across, so he tell you to stand up and touch the urinal thing.

Q. Did you touch the urinal? is that what he said, "Bend over and touch the urinal"?

A. Yeah.

Q. He said that to the other boys; is that right?

Q. Yeah.

Q. Is that before he paddled you or arfter he paddled you?

A. Before.

Q. What did he do when they stood over and leaned against the urinal?

A. Beat them.

Q. With what?...

A. A board.

Q. Do you remember how many licks he gave?

A. All different kind of licks. I mean all different kinds of numbers.

Q. Did they say anything?

A. Yeah, they say something.

Q. What did they say?

A. All kinds of stuff. They say--some of them hollering, cry, prayed and everything else. ...

Q. When did he paddle you; before, while he was paddling the fifteen boys, or after, or what?

A. After he paddle all of them, sending them out and then he paddled me.

Q. What did he tell you to do?

A. Same thing; stand behind the line and touch the urinate thing.

Q. Then did he paddle you?

A. No.

Q. Why not?

A. Because I ain't stand up there.

Q. Why is that?

A. I told him I could have made it if he...would have left me went.

Q. You mean made it to class? Is that what you mean?

A. Yeah.

Q. Then what happened?

A. Then he said something. I don't know what it was, and then he said, "Bend over, " and I ain't want to bend over, so he pushed me against the urinate thing, the bowl, and then he snatched me around to it and that's when he hit me first.

He first hit me on the backsides and then I stand up and he pushed me against the bathroom wall, them things--that part of the bathroom, the wall.

Q. The partition?

A. Between the toilets, he pushed me against that and then he snatched me from the back there and that's when he hit me on my leg, then he hit me on my arm, my back and then right across my neck, in the back here.

Q. Did those blows hurt?

A. Yeah, all of them hurt.

Roosevelt's father angrily protested the punishment at a meeting with Wright, Deliford and Barnes. This apparently had no effect on them, as Wright paddled Roosevelt within the next ten days, striking his buttocks and wrist and causing him to lose the full use of his wrist and arm for a week.

Student Rodney Williams was a victim of an auditorium number system at Drew Junior High School. The seats in the auditorium were numbered and if a student allegedly misbehaved the number was written on the blackboard by the teacher. Solomon Barnes would walk into the auditorium, call out the numbers, and administer four or five licks of the paddle to five to eight students daily. Rodney, who stood up from his seat to wipe off some grease, recalled the event:

A.... So he [the teacher] put my number on the board. So when Mr. Barnes came, he asked for me and took me to the office and told me to hook up.

Q. What did he mean by "hook up"?

A. Grab a chair, you know. The chair, he mean by hooking up on the chair.

Q. In preparation to being paddled.

A. So I refuse. I told him, I say, "Mr. Barnes, I didn't do nothing; that's why I refuse not to take a whipping."

Q. What did he do?

A. So he told me, say, "You are going to take this one."
I said, "Mr. Barnes, I didn't do nothing. I'm not taking no whipping."
So I was leaning over the table and I said "I'm not taking a whipping," and I was hit across the head with the board. He was hitting me across the head with the board, and my back and everything.

Q. He was whipping you where?

A. Across the head, with the board. He was hitting me all across the head and on the back. I was begging him for mercy to stop and he wouldn't listen.
So he had some chairs in there and I was falling in the chairs as he was hitting me with the board.
Then after a while he took off his belt and then started to hit me with the belt and hit me with the buckle part, and tears were coming out of me.

Rodney's head became swollen a few days later. He was anesthetized and a protuberance was lanced. "Pus and water and blood shot out." Rodney was out of school for a week and has a half-inch scar on the side of his forehead. Two other paddlings caused him to cough up blood.

The United States Supreme Court considered the constitutionality of these punishments in the 1977 decision of Ingraham v. Wright, 97, S.Ct. 1401 (1977). The Court held that the punishments administered to these and other students at Drew Junior High School did not violate the cruel and unusual punishment clause of the Eighth Amendment to the United States Consitiution. The Court also held that the due process clause of the Fourteenth Amendment to the United States Constitution does not require notification of charges and an informal hearing prior to the infliction of corporal punishment. The students of Dade County, Florida, had lost their case.

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