Bill is a student at the local high school. He was caught chewing tobacco in the boy's laboratory and sent to the principal's office. As punishment, the principal made him swallow the wad of tobacco, which immediately made Bill throw up. Bill went home and told his parents of the incident, and the next day they contacted a lawyer. Bill's lawyer then reads up on the case of Ingraham v Wright and realizes that a claim based on ____ would not succeed.