Brumfield v. Cain

Brumfield v. Cain

Argued March 30, 2015
Decided June 18, 2015
Full case name Kevan Brumfield v. Burl Cain, Warden
Docket nos. 13-1433
Citations

576 U.S. ___ (more)

2015 WL 2473376
Argument Oral argument
Opinion announcement Opinion announcement
Holding
Because Brumfield satisfied §2254(d)(2)’s requirements, he was entitled to have his Atkins claim considered on the merits in federal court.
Court membership
Chief Justice
John G. Roberts
Case opinions
Majority Sotomayor, joined by Kennedy, Ginsburg, Breyer, and Kagan
Dissent Thomas, joined by in all but Part 1-C by Roberts, Scalia, and Alito
Dissent Alito, joined by Roberts
Laws applied
U.S. Const. amend. VIII; 28 U. S. C. §§2254(d)(1), (2)

Brumfield v. Cain, 576 U.S. ___ (2015), was a United States Supreme Court case in which the Court held that because Brumfield satisfied 28 U.S.C. § 2254(d)(2)’s requirements, he was entitled to have his Atkins v. Virginia claim considered on the merits in federal court.

Background

Kevan Brumfield was sentenced to death for the 1993 murder of off-duty Baton Rouge police officer Betty Smothers. Brumfield, accompanied by another individual, shot and killed Officer Smothers while she was escorting the manager of a grocery store to the bank.[1] Smothers was the mother of Warrick Dunn, who later became a running back for the Tampa Bay Buccaneers and the Atlanta Falcons.

Brumfield had an IQ score of 75, had a fourth-grade reading level, had been treated at psychiatric hospitals as a child, had a learning disability, and had been placed in special education classes.[2] The lower courts denied Brumfield an Atkins hearing and sentenced him to death.[3]

Opinion of the Court

Justice Sonia Sotomayor delivered the opinion of the Court. She stated that the state's denial of Brumfield's request was based on an “unreasonable determination of the facts” in regards to his mental ability.[4] In addition, the state disregarded Brumfield's adaptive skills, or rather the adaptive impairments that prevented Brumfield from being able to process information.[5] By a 5–4 vote, the opinion of the lower court was vacated and the cause was remanded.[6]

Justice Clarence Thomas filed a dissent, arguing that since the majority still agreed with the factual record that supported the state court's decision, they cannot rule that the decision was "unreasonable" just because they would have reached a different conclusion.[7] Thomas also added a picture of Smothers in her police uniform in the appendix of his dissent.[8][9]

Justice Samuel Alito joined Justice Thomas' dissent in part, and then filed a second dissent to simply state that Thomas' inclusion of Warrick Dunn's life story as a contrast to Brumfield's, while inspiring, is not an essential part of the legal analysis.[10]

See also

References

  1. ↑ Brumfield v. Cain, No. 13-1433, 576 U.S. ___, 2015 WL 2473376 (June 18, 2015).
  2. ↑ Brumfield.
  3. ↑ Brumfield.
  4. ↑ Brumfield.
  5. ↑ Brumfield.
  6. ↑ Brumfield.
  7. ↑ Brumfield.
  8. ↑ Brumfield.
  9. ↑ "Justice Thomas's Dissent in the Brumfield Death-Penalty Case Shows Sympathy for the Victim, Not Her Killer". National Review. June 19, 2015. Retrieved October 21, 2015.
  10. ↑ Brumfield.

Further reading

External links

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