Ingraham et al. v. Wright et al.

Ingraham v. Wright has made it much more difficult for parents and students to oppose corporal punishments in the federal courts. Because the decision in Ingraham suggested that severe and unjustified punishments be pursued as civil or criminal cases in state court, victims of corporal punishment have no national standard for which to appeal. Instead, they must rely on each state's definition of what type of punishment is unreasonable and what type of relief should be offered.

Since Ingraham, a number of federal courts have either refused to hear or have ruled against students who suffered extreme corporal punishment, such as a girl whose teacher pricked her upper arm with a straight pin and a boy whose coach struck him eight times in the kidney area.

Although the Court found that procedural due process did not apply to corporal punishment, it did reserve the possibility that substantive due process might apply. Whereas procedural due process concerns the procedures that are needed before depriving someone of life, liberty, or property, substantive due process refers to the fact of someone having been deprived. In other words, a person who had suffered from a severe and unreasonable application of corporal punishment could not complain that he or she had not received a fair hearing. But that person could complain about what actually happened.

Thus, in the wake of Ingraham, one girl complained of being beaten with a five-inch wide rubber paddle, being shoved against a desk, and being "stricken repeatedly and violently," so that she had to go to the emergency room and to remain at the hospital for ten days. A federal court considered this treatment to have violated the girl's right to substantive due process under the Fourteenth Amendment. Yet because there were no clear federal guidelines as to the kind of punishment that warranted this ruling, other courts were reluctant to make similar decisions.

Ingraham v. Wright went a long way toward establishing the legitimacy of corporal punishment without any type of hearing or procedural constraint. Those who are opposed to either the use or the abuse of corporal punishment must now seek their remedies in state legislatures and courts.