Brumfield v. Cain

If an individual brings up an Atkins claim in regards to their intellectual capacity, and has fulfilled the requirements necessary for a hearing, then they are entitled to present evidence of their intellectual disability to the court.

Petitioner was sentenced to death for the murder of an off duty officer. In State v. Williams, the Louisiana Supreme Court held that an evidentiary hearing must be held when there is evidence that the individual has an intellectual disability. In Atkins v. Virginia the Court held that execution of an intellectually disabled person is a violation of the Eighth Amendment. Petitioner raised an Atkins claim because of his low IQ and poor reading ability. The trial court dismissed Petitioner’s claim without a hearing. The federal district court held that the rejection of Petitioner’s claim was incorrect and held that Petitioner was intellectually disabled. The Fifth Circuit reversed.

The Court looked at Petitioner’s low IQ score and determined that it could potentially be evidence of an intellectual disability diagnosis. Since there was no evidence of a higher IQ test score presented, the state court’s determination that it was not an intellectual disability was incorrect. The Court ruled that the state court’s refusal to grant an evidentiary hearing and its conclusion that Petitioner had impairment in adaptive skills was unreasonable. The Court held that Petitioner should have the opportunity to present his capacity to perform skills like self-care and learning to determine if he has an intellectual disability. The Court held that Petitioner presented enough evidence of a possible intellectual disability, and therefore, Petitoner can have his Atkins claim considered in federal court.