Supreme Court of the United States
Brumfield v. Cain
June 18, 2015576 U.S. 305
Summary
The Court held that the state court unreasonably determined the facts when it denied Brumfield an evidentiary hearing on his claim that intellectual disability barred his execution. His IQ score, evidence of adaptive impairments, and evidence of childhood developmental problems were sufficient to satisfy the federal habeas standard. The Court therefore vacated the Fifth Circuit’s judgment and remanded for further proceedings.
Holding
- Whether the state court unreasonably determined the facts in denying an evidentiary hearing on Brumfield’s intellectual-disability claim.. Brumfield satisfied the federal habeas requirement because the state court’s decision was based on unreasonable factual determinations.
- Whether an IQ score of 75 was inconsistent with intellectual disability.. The state court unreasonably treated an IQ score of 75 as foreclosing subaverage intellectual functioning.
- Whether the record contained sufficient evidence of adaptive impairment to warrant an evidentiary hearing.. The state court unreasonably determined that Brumfield had presented no evidence of adaptive impairment.
- Whether the state court made a factual determination rejecting evidence that Brumfield’s intellectual disability manifested during childhood.. The federal court was not required to defer to a developmental-stage determination because the state trial court made no such finding; in any event, the record supplied ample evidence creating reasonable doubt that the disability manifested before adulthood.
Docket 13-1433
Cited authorities
- 28 U.S.C. §§2254
- 28 U.S.C. §§2254
- Rule 15.2
- 28 U.S.C. §2254
- 28 U.S.C. §2254
- 28 U.S.C. §2254