Brumfield v. Cain Warden

Issues: , , ,



United States Supreme Court


135 S.Ct. 2269 (2015)
No. 13-1433
Argued: March 30, 2015????Decided: June 18, 2015


Petitioner Kevan Brumfield was convicted of murder in a Louisiana court and sentenced to death before this Court held that the Eighth Amendment prohibits execution of the intellectually disabled, Atkins v. Virginia, 536 U.?S. 304. Implementing Atkins‘ mandate, see id., at 317, the Louisiana Supreme Court determined that an evidentiary hearing is required when a defendant “provide[s] objective factors” sufficient to raise a “?’a reasonable ground’?” to believe that he has an intellectual disability, which the court 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.” State v. Williams, 2001-1650 (La. 11/1/02), 831 So. 2d 835, 857, 861, 854.

Soon after the Williams decision, Brumfield amended his pending state postconviction 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 Brumfield’s petition without holding a hearing or granting funds to conduct additional investigation. Brumfield subsequently sought federal habeas relief. The District Court found that the state court’s rejection of Brumfield’s claim was both “contrary to, or involved an unreasonable application of clearly established Federal law, as determined by” this Court and “based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding.” 28 U.?S.?C. ??2254(d)(1), (2). The court went on to determine that Brumfield was intellectually disabled. The Fifth Circuit found that Brumfield’s petition failed to satisfy either of ?2254(d)’s requirements and reversed.

Held:?Because Brumfield satisfied ?2254(d)(2)’s requirements, he was entitled to have his Atkins claim considered on the merits in federal court. Pp.?6-19.

(a)?The two underlying factual determinations on which the state trial court’s decision was premised–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 ?2254(d)(2). Because that standard is satisfied, the Court need not address ?2254(d)(1). Pp.?6-17.

(1)?Expert trial testimony that Brumfield scored a 75 on an IQ test is entirely consistent with intellectual disability. Every IQ score has a margin of error. Accounting for that margin of error, the sources on which the Williams court relied in defining subaverage intelligence describe a score of 75 as consistent with an intellectual disability diagnosis. There was no evidence presented to the trial court of any other IQ test that was sufficiently rigorous to preclude the possibility that Brumfield possessed subaverage intelligence. Pp.?8-11.

(2)?The state-court record contains sufficient evidence to suggest that Brumfield would meet the criteria for adaptive impairment. Under the test most favorable to the State, an individual like Brumfield must show a “substantial functional limitation” in three of six “areas of major life activity.” Williams, 831 So.?2d, at 854. Brumfield–who was placed in special education classes at an early age, was suspected of having a learning disability, and can barely read at a fourth-grade level–would seem to be deficient in two of those areas: “[u]nderstanding and use of language” and “[l]earning.” Ibid. His low birth weight, his commitment to mental health facilities at a young age, and officials’ administration of antipsychotic and sedative drugs to him at that time all indicate that he may well have had significant deficits in at least one of the remaining four areas. In light of that evidence, the fact that the record contains some contrary evidence cannot be said to foreclose all reasonable doubt as to his intellectual disability. And given that Brumfield’s trial occurred before Atkins, the trial court should have taken into account that the evidence before it was sought and introduced at a time when Brumfield’s intellectual disability was not at issue. Pp.?11-17.

(b)?The State’s two additional arguments are rejected. Because the State did not press below the theory that ?2254(e)(1) supplies the governing standard when evaluating whether a habeas petitioner has satisfied ?2254(d)(2)’s requirements, that issue is not addressed here. And because the state trial court made no finding that Brumfield had failed to produce evidence suggesting he could meet the “manifestations .?.?. in the developmental stage” requirement for intellectual disability, there is no determination on that point to which a federal court must defer in assessing whether Brumfield satisfied ?2254(d). In any event, the state court record contained ample evidence creating a reasonable doubt as to whether Brumfield’s disability manifested before adulthood. Pp.?17-18.

744 F.?3d 918, vacated and remanded.

SOTOMAYOR, J., delivered the opinion of the Court, in which KENNEDY, GINSBURG, BREYER, and KAGAN, JJ., joined. THOMAS, J., filed a dissenting opinion, in all but Part I-C of which ROBERTS, C.?J., and SCALIA and ALITO, JJ., joined. ALITO, J., filed a dissenting opinion, in which ROBERTS, C.?J., joined.