783 F.3d 212
5th Cir.2015Background
- John Reyes Matamoros was convicted of capital murder in Texas (1992) and sentenced to death; he later sought habeas relief claiming intellectual disability under Atkins v. Virginia.
- Texas courts and a state habeas trial court initially denied relief; the Texas Court of Criminal Appeals (TCCA) found Matamoros met the IQ prong but not adaptive-functioning deficits or onset before 18.
- Federal habeas proceedings were stayed to permit state exhaustion after the State’s expert, Dr. George Denkowski, was reprimanded in 2011 and agreed to stop performing certain forensic evaluations.
- The TCCA remanded for reconsideration; the trial court amended findings disclaiming reliance on Denkowski but largely replicated its prior conclusions; TCCA again denied relief after its own review.
- Matamoros argued the TCCA’s decision was an unreasonable factual determination under 28 U.S.C. § 2254(d)(2); he presented expert testimony (Dr. Susana Rosin) and historical testing showing low IQs and adaptive deficits, while the State relied on historical custodial records and behavioral evidence.
- The Fifth Circuit applied AEDPA deference and Briseno’s adaptive-behavior framework, concluded Matamoros failed to rebut the state court’s factual findings by clear and convincing evidence, and affirmed the denial of habeas relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether TCCA’s finding that Matamoros lacked adaptive deficits was an unreasonable factual determination under §2254(d)(2) | Matamoros: record (IQ tests, experts, historic records) shows adaptive deficits before 18 and Denkowski’s discredited testimony tainted prior findings | State/TCCA: historical records, prison/TYC behavior, and testimony show sufficient adaptive functioning; TCCA independently reviewed the record and need not rely on Denkowski | Held: TCCA’s conclusion was not unreasonable; petitioner failed to rebut state findings by clear and convincing evidence |
| Whether Dr. Denkowski’s reprimand requires granting relief or remand | Matamoros: Denkowski’s methodology was unreliable and its prior use infected the factfinding | State/TCCA: TCCA conducted its own review and did not rest outcome solely on Denkowski; remand unnecessary | Held: Denkowski’s reprimand did not render the TCCA decision unreasonable; federal review limited to state-court decision and record |
| Proper standard for assessing intellectual disability under Texas law | Matamoros: courts should follow clinical standards and Hall v. Florida cautions against nonclinical deviations | State/TCCA: Texas follows Briseno factors alongside AAMR criteria; Briseno is binding in this circuit | Held: Briseno framework is constitutionally permissible and controls the analysis in this circuit |
| Whether newly tendered affidavits (Fletcher, Oakland) required a new factual inquiry | Matamoros: affidavits critique Denkowski and support adaptive deficits, so courts must reconsider | State/TCCA: affidavits were not required or controlling; finder of fact may weigh historical/observational evidence | Held: Even if considered, affidavits would not compel relief under Briseno/AEDPA; outcome unchanged |
Key Cases Cited
- Atkins v. Virginia, 536 U.S. 304 (Sup. Ct. 2002) (Eighth Amendment bars execution of intellectually disabled offenders)
- Ex parte Briseno, 135 S.W.3d 1 (Tex. Crim. App. 2004) (Texas test for intellectual disability; Briseno factors for adaptive behavior)
- Hall v. Florida, 134 S. Ct. 1986 (Sup. Ct. 2014) (criticized strict IQ cutoffs; emphasized adherence to clinical standards)
- Harrington v. Richter, 562 U.S. 86 (Sup. Ct. 2011) (deference standard under AEDPA)
- Wood v. Allen, 558 U.S. 290 (Sup. Ct. 2010) (state-court factual findings not unreasonable merely because reasonable minds might disagree)
- Rice v. Collins, 546 U.S. 333 (Sup. Ct. 2006) (federal habeas courts review state-court factfinding for unreasonableness)