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Brumfield v. Cain

Justia Summary

Brumfield was convicted of murder in a Louisiana court and sentenced to death before the Supreme Court held, in Atkins v. Virginia, that the Eighth Amendment prohibits execution of the intellectually disabled. The Louisiana Supreme Court subsequent determined that an evidentiary hearing is required when a defendant provides objective factors sufficient to raise a “a reasonable ground’” to believe that he has an intellectual disability, defined as “(1) subaverage intelligence, as measured by objective standardized IQ tests; (2) significant impairment in several areas of adaptive skills; and (3) manifestations of this neuro-psychological disorder in the developmental stage.” Brumfield amended his pending state post-conviction petition to raise an Atkins claim. Seeking an evidentiary hearing, he pointed to evidence introduced at sentencing that he had an IQ of 75, had a fourth-grade reading level, had been prescribed numerous medications and treated at psychiatric hospitals as a child, had been identified as having a learning disability, and had been placed in special education classes. The trial court dismissed without holding a hearing or granting funds to conduct additional investigation. Brumfield sought federal habeas relief. The district court granted relief under 28 U.S.C. 2254(d)(1), (2). The Fifth Circuit reversed. The Supreme Court vacated and remanded. The factual determinations underlying the state trial court’s decision—that Brumfield’s IQ score was inconsistent with a diagnosis of intellectual disability and that he presented no evidence of adaptive impairment—were unreasonable under section 2254(d)(2). The fact that the record contains some contrary evidence cannot be said to foreclose all reasonable doubt as to his intellectual disability. The trial court should have taken into account that the evidence was introduced before Brumfield’s intellectual disability was at issue.

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