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.
Questions
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?
Conclusions
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Yes. Justice Sonia Sotomayor delivered the opinion of the 5-4 majority. The Court held that the state trial court’s decision that Brumfield did not present sufficient evidence of mental impairment was an unreasonable determination of the facts, and therefore the federal district court could review the state court’s decision. The state court’s decision rested on its determination that Brumfield’s IQ score was not low enough to prove that he had subaverage intelligence and that Brumfield did not show that his adaptive skills were impaired. However, an IQ test has a margin of error that, if applied to the score in this case, would place Brumfield in the category of subaverage intelligence; therefore, the state court could not definitively preclude the possibility that Brumfield satisfied this criterion, and to hold otherwise was unreasonable. Additionally, the factual record presented to the state court provided sufficient evidence to question Brumfield’s adaptive skills. Because Brumfield only needed to raise reasonable doubt regarding his intellectual capacity to be entitled to an evidentiary hearing, the state court’s decision that Brumfield did not meet that low threshold was unreasonable.
Justice Clarence Thomas wrote a dissenting opinion in which he argued that judicial precedent establishes that, as long as the factual record supports the state court’s decision, a federal court cannot rule that decision unreasonable simply because it would have concluded differently. In this case, the record showed that Brumfield’s IQ score was not low enough for him to be declared of subaverage intelligence and that he did not have impaired adaptive skills because he had a normal capacity to learn when given time for repetition. Because the factual record supported the state court’s determination that Brumfield was not intellectually disabled based on the relevant state standards to prove intellectual disability, the determination was reasonable. Justice Thomas also wrote that Brumfield’s claim could not succeed based on the argument that the state court’s decision was contrary to clearly established federal law, which is a high standard that requires the habeas petitioner to show that the state court confronted a set of facts “materially indistinguishable” from a Supreme Court case and nonetheless reached a different conclusion. In this case, Brumfield could not show that the Supreme Court had ever decided a case with facts materially indistinguishable from this one, and the state court’s decision was in line with existing precedent; therefore the state court’s decision was not contrary to clearly established federal law. Chief Justice John G. Roberts, Jr. and Justice Antonin Scalia joined in the dissent. Justice Samuel A. Alito, Jr. also joined Justice Thomas’ dissent in part and wrote separately to note that Justice Thomas’ inclusion of the life story of the victim’s son in his dissent should not be considered a part of the legal analysis.
SCOTUS Opinions: 6/18/2015
(1) Brumfield v. Cain: By a vote of 5-4 the judgment of the Fifth Circuit...
