Brumfield v. Cain

Kevan Brumfield (defendant) was convicted of the murder of an off-duty police officer, Betty Smothers, and sentenced to death. While his state postconviction petition was pending, Brumfield raised an Atkins claim, pursuant to Atkins v. Virginia, 536 U.S. 304 (2002), seeking an evidentiary hearing on the issue of whether Brumfield was intellectually disabled and ineligible for the death penalty. The trial court dismissed Brumfield’s position, finding he was not entitled to an evidentiary hearing. The court determined that the evidence presented at trial regarding Brumfield’s mental capacity was sufficient to conclude that he was not intellectually disabled. Such evidence included expert testimony and reports indicating Brumfield had an IQ of 75 (under 70 is strong evidence of intellectual disability) and an antisocial personality disorder. The Louisiana Supreme Court denied Brumfield’s application for review. Brumfield filed a habeas corpus petition in federal court. The district court found that the state’s denial of an Atkins hearing for Brumfield violated the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), 28 U.S.C. §§ 2254(d)(1), (2). The district court held that Brumfield was mentally retarded and ineligible for execution. The United States Court of Appeals for the Fifth Circuit reversed the district court judgment, holding that the requirements of § 2254(d) had not been satisfied. The United States Supreme Court granted certiorari.