Brumfield v. Cain

PETITIONER: Kevan Brumfield
RESPONDENT: Burl Cain
LOCATION: United States Court of Appeals for the Fifth Circuit

DOCKET NO.: 13-1433
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Fifth Circuit

CITATION: 576 US (2015)
GRANTED: Dec 05, 2014
ARGUED: Mar 30, 2015
DECIDED: Jun 18, 2015

ADVOCATES:
Michael B. DeSanctis - for the petitioner
Premila Burns - for the respondent

Facts of the case

In 1995, Kevan Brumfield was convicted of the murder of a Louisiana police officer and sentenced to death. After the Supreme Court decided Atkins v. Virginia in 2002, which held the execution of mentally retarded criminals violated the Eighth Amendment's prohibition of cruel and unusual punishment, Brumfield filed for post-conviction relief on the basis that he was mentally retarded. Brumfield also requested funds to help develop his Atkins claim. The Louisiana state court found that Brumfield was not entitled to an Atkins hearing because Brumfield did not present enough evidence to establish he was mentally impaired. The Louisiana Supreme Court denied his appeal without explanation.

Brumfield next filed a petition for a writ of habeas corpus in federal court and argued that the state courts had erred in failing to give him a full Atkins hearing. He also requested funding to enable him to fully present his claims, which was granted. A federal magistrate found that, while the state court had correctly ruled that Brumfield's initial evidence regarding his mental retardation was not adequate for the court to have granted Atkins relief, the additional funds enabled Brumfield to establish a prima facie case of mental retardation. The federal magistrate subsequently recommended that the district court admit Brumfield's new evidence when determining his habeas claim; the district court did so and ruled in favor of Brumfield by forbidding Louisiana from executing him. The U.S. Court of Appeals for the Fifth Circuit reversed and held that the state court's ruling on Brumfield's Atkins claim constituted a decision on the merits, so the Antiterrorism and Effective Death Penalty Act prevented the district court from reviewing the decision unless the state court's decision was contrary to clearly established federal law or based on an unreasonable determination of the facts. Because the state denied Brumfield additional funds to develop his case due to his failure to establish a prima facie case of mental retardation, the decision was not a violation of Brumfield's constitutional due process rights nor based on an unreasonable determination of the facts.

Question

Is a state court's denial of an Atkins claim, when the defendant has not had the opportunity or funds to develop the claim, a decision based on an unreasonable determination of the facts?

Media for Brumfield v. Cain

Audio Transcription for Opinion Announcement - June 18, 2015 in Brumfield v. Cain

John G. Roberts, Jr.:

Justice Sotomayor has our opinion this morning in case 13-1433 Brumfield v. Cain.

Sonia Sotomayor:

This case comes to us from the Court of Appeals for the Fifth Circuit.

Petitioner Kevan Brumfield was convicted of murder and sentenced to death.

Subsequently, this Court held in Atkins v. Virginia that the execution of the intellectually disabled contravenes the Eighth Amendment.

Brumfield sought an opportunity to prove he was intellectually disabled, but the Louisiana State Court rejected his appeal -- his request.

Brumfield then filed the petition for habeas corpus in federal court.

To secure relief Brumfield was required to show among other things that the State Court's decision was based on an unreasonable determination of the facts.

The District Court found that it was.

Then, relying on new evidence, the District Court determined that Brumfield is intellectually disabled, but the Fifth Circuit reversed, holding that Brumfield had failed to show that the State Court's rejection of his Atkins claim was based on an unreasonable determination of the facts.

We vacate and remand for further proceedings.

To obtain a hearing in State Court, Brumfield needed only to point to evidence raising a reasonable ground to believe him to be intellectually disabled.

The State Court's refusal to grant him such a hearing was premised on two underlying factual determinations, that his reported IQ test result of 75 was inconsistent with intellectual disability and that he had failed to provide any evidence of adaptive impairment.

The first of these determinations we conclude was unreasonable.

All IQ test results have a margin of error.

Accounting for this margin of error, Brumfield's 75 was squarely within the range of intellectual disability.

The State Court's second factual determination was also unreasonable.

Brumfield pointed to ample evidence of his adaptive impairments including trial testimony that he had been at risk of neurological traumas at birth, was diagnosed with a learning disability and placed in special education classes, was committed to mental health facilities and given powerful medications, reads at a fourth-grade level, and simply cannot process information.

Accordingly, we hold that the State Court's decision was based on an unreasonable determination of the facts and that Brumfield was therefore entitled to have a Federal District Court consider his Atkins claims on the merits.

The judgment of the Fifth Circuit is vacated, and the case is remanded for further proceedings.

Justice Thomas has filed a dissenting opinion in which the Chief Justice, Justice Scalia, and Justice Alito joined acceptance to Part 1C.

Justice Alito has filed the dissenting opinion in which the Chief Justice joins.