Maldonado v. Thaler
2010 U.S. App. LEXIS 22590
5th Cir.2010Background
- Maldonado, a Mexican national, was sentenced to death for capital murder during a 1995 robbery in Texas.
- He confessed to the murder after his arrest for an unrelated bank robbery, detailing a multi-person plan to kill the victim.
- Post-conviction state appeals culminated in a Briseno framework adjudicating mental retardation claims for Atkins purposes.
- Maldonado sought federal habeas relief under 28 U.S.C. § 2254 after exhausting state remedies; district court denied relief and a COA except on Atkins claim.
- The district court considered new revelations about Dr. Denkowski’s testing in Plata and a State Board complaint, but upheld the state court’s finding Maldonado was not mentally retarded.
- The Fifth Circuit affirmed, holding that disregarding Denkowski’s testimony still leaves insufficient evidence to meet Briseno’s three-prong standard.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Denkowski’s testing flaws require disregarding his testimony | Maldonado argues Denkowski’s methodology invalidates his testimony. | Thaler contends the state court reasonably credited remaining evidence and did not rely on flawed methodology. | No; the court found the remaining evidence insufficient to meet Briseno. |
| Whether Denkowski’s upward score adjustments undermine reliability | Adjustments reflect unreliable cultural/education factors and interpreter issues. | State court properly weighed and found adjustments do not establish MR under Briseno. | No; even disregarding Denkowski’s testimony, Maldonado fails Briseno. |
| Whether the remaining evidence shows Maldonado meets Briseno prongs | There is adaptive deficit and cognitive impairment evidence supporting MR. | Record shows no significant adaptive deficits and intellectual functioning not subaverage under Briseno. | No; record does not rebut the state court’s Briseno-based finding. |
| Proper AEDPA standard of review for state court decisions | District court should reweigh the evidence de novo given new issues. | Review is for unreasonable application of law or unreasonable factual determination under §2254(d). | Affirmed; a reasonable application of law and facts supported the denial. |
| Role of Briseno framework within Atkins in Texas | Briseno framework misapplied or too rigid for this record. | Briseno provides the constitutionally required standard and ultimate fact finder is the court. | Affirmed; Briseno framework properly applied. |
Key Cases Cited
- Atkins v. Virginia, 536 U.S. 304 (U.S. 2002) (Eighth Amendment prohibits execution of mentally retarded individuals)
- Ex parte Briseno, 135 S.W.3d 1 (Tex.Crim.App. 2004) (three-prong Briseno framework for mental retardation)
- Williams v. Taylor, 529 U.S. 362 (U.S. 2000) (unreasonable application standard under AEDPA)
- Renico v. Lett, 130 S. Ct. 1855 (U.S. 2010) (unreasonable determinations of fact must be objectively unreasonable)
- Moore v. Quarterman, 342 Fed.Appx. 65 (5th Cir. 2009) (adaptive deficits and interpretive testing considerations under Briseno)
- Wiley v. Epps, 625 F.3d 199 (5th Cir. 2010) (case-based evaluation of MR under Atkins; reasonableness standard)