Joseph Clifton Smith v. Donal Campbell
620 F. App'x 734
11th Cir.2015Background
- Smith, a death-row inmate, pursues federal habeas relief under 28 U.S.C. § 2254 on an Atkins claim of intellectual disability.
- Alabama courts denied Smith’s Atkins claim without an evidentiary hearing; district court likewise denied relief.
- The murder of Durk Van Dam in 1997 is the overarching crime; Smith’s trial produced multiple statements and evidence of violent, gruesome killing.
- At trial, three aggravating factors were found; defense presented mitigating evidence including Dr. Chudy’s IQ assessment and learning disabilities.
- Smith’s state post-conviction Rule 32 petitions asserted intellectual disability under Perkins; Alabama courts dismissed without an evidentiary hearing, applying the pleading and merits standards.
- The federal court granted a COA on three Atkins-related issues and ultimately remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Rule 32.6(b) pleading adequacy | Smith argues the record supports non-conclusory grounds for Atkins. | State contends the petition relied on conclusory allegations and lacked supported facts. | Rule 32.6(b) ruling unreasonable; facts pleaded support Atkins grounds. |
| Adaptive behavior deficits | Smith showed substantial adaptive-behavior deficits before 18 under Atkins. | State court found no significant adaptive impairment in the record. | Merits determination on adaptive behavior is unreasonable; remand warranted. |
| Intellectual functioning deficits | Trial/testimony showed subaverage functioning (IQ around 72 with measurement error considerations). | Record does not demonstrate subaverage functioning under Alabama’s approach. | Merits determination on intellectual functioning unreasonable; remand warranted. |
Key Cases Cited
- Atkins v. Virginia, 536 U.S. 304 (U.S. 2002) (execution of mentally retarded offenders violates Eighth Amendment)
- Perkins v. State, 851 So.2d 453 (Ala. 2002) (three-prong framework for mental retardation under Alabama law)
- Brumfield v. Cain, 576 U.S. _ (U.S. 2015) (reaffirms analysis of adaptive impairment and IQ scores)
- Wiggins v. Smith, 539 U.S. 510 (U.S. 2003) (state court factual determinations under AEDPA can be unreasonable)
- Crawford v. Campbell, 311 F.3d 1326 (11th Cir. 2002) (underlines standards for evaluating merits of Atkins claims)
- Brumfield v. Cain, 135 S. Ct. 2269 (U.S. 2015) (clarifies IQ score interpretation under Atkins framework)
- Hill v. Humphrey, 662 F.3d 1335 (11th Cir. 2011) (AEDPA deference and standards for habeas review)
- Cullen v. Pinholster, 563 U.S. 170 (U.S. 2011) (restricts new evidence in federal review to the state-court record)