Brumfield v. Cain
2012 U.S. Dist. LEXIS 22817
M.D. La.2012Background
- Brumfield filed a federal habeas petition seeking Atkins relief to prove mental retardation and ineligibility for the death penalty.
- An Atkins evidentiary hearing was held in 2010 after Brumfield’s state post-conviction claims were denied.
- Brumfield was convicted of capital murder in 1995; the Louisiana Supreme Court affirmed, and the U.S. Supreme Court denied cert.
- In 2000 Brumfield sought post-conviction relief in state court; funding for experts to develop his Atkins claim was repeatedly sought but denied.
- The district court conducted a full Atkins hearing and later ruled the petition warranted relief on the Atkins claim, granting relief only to the extent Brumfield is ineligible for execution.
- The State challenged the Atkins hearing decision via a converted motion for reconsideration based on newly decided law; the court denied the challenge and reaffirmed the Atkins hearing and its merits ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the state court’s denial of an Atkins evidentiary hearing violated AEDPA | Brumfield satisfied prima facie Atkins case; denial was unreasonable | State contends evidence was insufficient to trigger a hearing | Yes; denial violated AEDPA and Brumfield was entitled to a full Atkins hearing. |
| Whether the state court’s merits determination on Atkins was unreasonable under § 2254(d)(1) and (d)(2) | State court misapplied Atkins and misread evidence, lacking deference | State court properly weighed evidence and applied legal standards | Yes; state court erred both in law and in evaluating factual record for Atkins claim. |
| Whether Brumfield demonstrated intellectual functioning prong and adaptive behavior prong under AAIDD definitions | IQ scores and Flynn Effect-adjusted results show significant impairment | Scores and adaptive-skill evidence do not meet criteria | Prong One met; Prong Two met based on holistic, retrospective assessment under AAIDD 10th Edition. |
| Whether etiology and onset before age 18 established by pre-Atkins evidence support retroactive diagnosis | Pre-adult risk factors and social history support retardation | Lack of pre-Atkins diagnosis undermines retroactive finding | Yes; substantial etiological and pre-18 onset evidence supports retroactive finding of retardation. |
Key Cases Cited
- Atkins v. Virginia, 536 U.S. 304 (2002) (death penalty unconstitutional for mentally retarded; states define retardation)
- Panetti v. Quarterman, 551 U.S. 930 (2007) (due process considerations in competency/retardation context)
- Richter v. Collins?, 131 S. Ct. 770 (2011) (AEDPA deference and factual determinations analyzed)
- Wiley v. Epps, 625 F.3d 199 (5th Cir. 2010) (AEDPA deference when state court refuses hearing on prima facie retardation)
- Hall v. Quarterman, 534 F.3d 365 (5th Cir. 2008) (retardation/competency distinctions in Atkins context)
- Rivera v. Quarterman, 505 F.3d 349 (5th Cir. 2007) (due process and full hearing requirements in Atkins claims)
- McCamey v. Epps, 658 F.3d 491 (5th Cir. 2011) (interaction of 2254(d) and 2254(e)(2) in evidentiary hearings)
- Moore v. Quarterman, 491 F.3d 213 (5th Cir. 2007) (AEDPA exhaustion considerations in Atkins context)