Brumfield v. Cain, 576 U.S. __, 135 S. Ct. 2269 (Jun. 18, 2015)

Because the Louisiana state court’s decision rejecting the defendant’s Atkins claim without affording him an evidentiary hearing was based on an unreasonable determination of the facts, the defendant was entitled to have his claim considered on the merits in federal court. After the defendant was convicted, the U.S. Supreme Court held, in Atkins, that “in light of . . . ‘evolving standards of decency,’” the Eighth Amendment “‘places a substantive restriction on the State’s power to take the life’ of a mentally retarded offender.” The Court however left “to the State[s] the task of developing appropriate ways to enforce the constitutional restriction upon [their] execution of sentences.” The Louisiana Supreme Court later held that “a diagnosis of mental retardation has three distinct components: (1) subaverage intelligence, as measured by objective standardized IQ tests; (2) significant impairment in several areas of adaptive skills; and (3) manifestations of this neuro-psychological disorder in the developmental stage.” That court further held that an Atkins evidentiary hearing is required when an inmate has put forward sufficient evidence to raise a “reasonable ground” to believe him to be intellectually disabled. In a post-conviction motion in the case at bar, the defendant sought an Atkins hearing. Without holding an evidentiary hearing or granting funds to conduct additional investigation, the state trial court dismissed the defendant’s petition. After losing in state court, the defendant pursued federal habeas relief. The defendant won at the federal district court but the Fifth Circuit reversed. The U.S. Supreme Court granted review and held that the state court’s decision denying his Atkins claim was premised on an “unreasonable determination of the facts.” In reaching this decision, the Court focused on the two underlying factual determinations on which the trial court’s decision was premised: that the defendant’s IQ score of 75 was inconsistent with a diagnosis of intellectual disability and that he had presented no evidence of adaptive impairment. The Court held that both of the state court’s critical factual determinations were unreasonable.