Brumfield v. Cain (13-1433)
argument 13-1433Brumfield v. Cain
Supreme Court of the United States
59 min
6 speakers
8 chapters
transcribed 4 days ago
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What is the central legal issue in Brumfield v. Cain regarding intellectual disability claims?
We'll hear an argument this morning in Case 13-1433, Brumfield v. Kane. Mr. DeSantis.
Mr. Chief Justice, and may it please the Court. The decision of the State Court in this case was to deny Kevin Brumfield a hearing on his claim of intellectual disability. That decision was based on an entirely unreasonable determination of the facts of Brumfield's mental conditions. The Court specifically, the Court expressly stated in its decision to deny a hearing was, quote, based on the three bases that it laid out in its oral ruling at page 172 of the PEDAP, and I'd like to discuss each of those in turn. The first basis given by the state court was that Brumfield scored a 75 on the Wexler IQ test. That's not just suggestive of intellectual disability. That's actual evidence of intellectual disability.
And there was no testimony in the record to the contrary. This court made it clear in Atkins. All of the clinical texts on which this court relied on in Atkins make it clear. And the Louisiana Supreme Court had made it clear in Williams and in Dunn. The second evidence basis for the State Court's decision was that the defendant has not, quote, demonstrated impairment based on this record in adaptive skills. To demand or even expect that blood from the stone of a pre-Atkins record where neither intellectual disability nor adaptive skills were even raised
is patently unreasonable. I don't, whether I agree with you or not, isn't it your burden to prove that he had some deficits in adaptive ability, you have to make the threshold showing.
MR. Yes, there's a threshold showing under Louisiana
law. JUSTICE BREYER- So what did you show that met that prong in any way?
MR. Sure. The standard under Louisiana law is a low one. It's a burden of coming forward with some evidence of objective facts that put the movement's intellectual disability at issue. JUSTICE
BREYER- How is that determination under State law pertinent to the question here?
I was merely answering Justice Sotomayor's question as to what facts were put into evidence before the State Court. I was setting the State — Well, I understand
that. But given the facts that were presented — this is what the language of the law is, of course — and the evidence presented in the State Court proceeding, how is that pertinent on the Federal question? In other words, I don't think it would be a different — Your burden, I don't think, would be different on the question that's presented here if the state law required a higher threshold or not.
And we're not requiring — we're not challenging the state law. But in your
answer to Justice Sotomayor, I thought you said, well, the state has a very low standard. What difference does that make? Are you saying that If the State, with its regular processes, takes a Federal rule and misinterprets the rule as part of its process, then there's a Federal violation. Is that your point?
No. There could be in that case, but that's not our
argument. What difference does it make, and I think this was what the Chief Justice's concern was as well, what difference does it make that Louisiana has a low bar or a high bar?
It may not make a difference, Your Honor, and it's not a critical part of our argument.
And then while you're on this, suppose at the trial, in the sentencing phase, an expert, medical expert testified, in my view, this defendant does not have an intellectual disability as we define that in medical terms. Would you be here?
It's a hypothetical, of course. It's a hypothetical. Obviously, that wasn't this case. There was no testimony at the state trial or sentencing about intellectual disability. But in that case, we probably still would be here because that's what happened in Williams. In Williams 1, the Defense's own expert at trial prior to Atkins had testified that the defendant was not intellectually disabled, and yet the Louisiana Supreme Court sent it back for an Atkins hearing because Atkins had entirely changed the legal landscape. Well,
the first question presented in your petition is whether a State Court that considers the evidence presented at a petitioner's penalty phase proceeding as determinative of the petitioner's claim of intellectual disability under Atkins has based its decision
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Chapters
8 chapters
1
What is the central legal issue in Brumfield v. Cain regarding intellectual disability claims?
0:00–8:08
2
How did the State Court justify denying a hearing based on Brumfield’s IQ score of 75?
8:08–15:48
3
Why did the defense argue that adaptive‑skill evidence was improperly ignored?
15:48–22:41
4
What role does the Atkins precedent play in determining the need for a hearing?
22:41–29:52
5
How did the parties interpret Louisiana’s “low‑bar” standard for intellectual disability?
29:52–37:45
6
What evidence of mental impairment did the record actually contain?
37:45–46:10
7
Why is the question of funding for expert testimony crucial to the case?
46:10–53:14
8
What is the Supreme Court’s ultimate conclusion about the constitutionality of the State Court’s decision?
53:14–59:51