Brumfield v. Cain

Whether (1) exclusive reliance on findings made during the penalty phase of a trial is an unreasonable determination of facts under 28 U.S.C. § 2254(d) for making an Atkins analysis; and (2) whether a state's denial of resources for post-trial evidentiary examinations denies a defendant the "opportunity to be heard" and to mount an adequate defense.

This case arises from the 1995 conviction and death sentence imposed against Petitioner by the State of Louisiana. Petitioner filed a federal habeas claim against Respondent that asserted he was mentally retarded and ineligible for capital punishment under Atkins v. Virginia, 536 U.S. 304 (2002), which prohibited the imposition of the death penalty for such persons. The district court granted a permanent injunction based on the evidentiary hearing regarding whether he was mentally retarded per Atkins. The Fifth Circuit reversed. Petitioner sought a writ of certiorari in part because the decision created a circuit split with regard to the procedure and evidence used to grant relief under Atkins, which affects all current and future capital cases.

Petitioner asserts that the Fifth Circuit relied on an unreasonable determination of facts by the state court during the penalty phase of the state court hearing in 1995, holding they were on the merits and deserved deference under 28 U.S.C. § 2254(d), rather than the 2010 hearing relied upon by the district court. The Fifth Circuit determined that the state court complied with the Atkins test in its application of state law determining whether a person is mentally retarded. Petitioner also claims that the state’s denial of indigent support denied and a subsequent evidentiary hearing violated his right to be heard and to mount an adequate defense. The Fifth Circuit held that because the state court decision was on the merits per 28 U.S.C. § 2254(d), that no further support was required. The Supreme Court granted certiorari on these issues.