Brumfield v. Cain
Brumfield v. Cain, 576 U.S. 305 (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,[1] he was entitled to have his Atkins v. Virginia[2] claim considered on the merits in federal court.
| Brumfield v. Cain | |
|---|---|
 | |
| Argued March 30, 2015 Decided June 18, 2015 | |
| Full case name | Kevan Brumfield v. Burl Cain, Warden |
| Docket no. | 13-1433 |
| Citations | 576 U.S. 305 (more) 135 S. Ct. 2269; 192 L. Ed. 2d 356; 2015 WL 2473376 |
| Argument | Oral argument |
| Opinion announcement | Opinion announcement |
| Case history | |
| Prior | Writ of habeas corpus granted, 854 F. Supp. 2d 366 (M.D. La. 2012); reversed, 744 F.3d 918 (5th Cir. 2014); cert. granted, 135 S. Ct. 752 (2014). |
| Subsequent | On remand, 808 F.3d 1041 (5th Cir. 2015); cert. denied, 136 S. Ct. 2411 (2016). |
| 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 | |
| |
| Case opinions | |
| Majority | Sotomayor, joined by Kennedy, Ginsburg, Breyer, Kagan |
| Dissent | Thomas, joined by in all but Part 1-C by Roberts, Scalia, Alito |
| Dissent | Alito, joined by Roberts |
| Laws applied | |
| U.S. Const. amend. VIII; | |
Background
Kevan Brumfield (born January 7, 1973)[3] was sentenced to death for the January 7, 1993 murder of off-duty Baton Rouge police officer Betty Smothers. Brumfield and his accomplice, Henri Broadway (born September 7, 1970),[3] shot and killed Officer Smothers while she was escorting the manager of a grocery store to the bank.[4] 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.[4] The lower courts denied Brumfield an Atkins hearing and sentenced him to death.[4]
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.[4] By a 5–4 vote, the opinion of the lower court was vacated and the cause was remanded.[4]
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.[4] Thomas also added a picture of Smothers in her police uniform in the appendix of his dissent.[4][5]
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.[4]
Subsequent developments
On July 20, 2016, Brumfield was resentenced to life in prison after he was ruled intellectually disabled and therefore ineligible for execution.[6] Broadway remains on death row for his involvement in the murder, although it was Brumfield who actually fired the fatal shots which killed Smothers, Broadway had been the one to wound the grocery store manager.[7] The getaway driver, West Paul, was sentenced to twenty-five years for his role in the murder. Paul was returned to jail in 2017 after he was booked on charges related to shoplifting. Prior to his return to jail he had only recently been released for his part in the murder of Smothers.[8]
See also
References
- .
- Atkins v. Virginia, 536 U.S. 304 (2002).
- "VINE Empowered by information". vinelink.com.
- Brumfield v. Cain, No. 13-1433, 576 U.S. ___ (2015).
- "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.
- "Longtime death-row inmate Kevan Brumfield gets life in 1993 Baton Rouge cop-killing". The Advocate. 20 July 2016.
- "Court: Jury's gambling no reason to overturn conviction in 1993 Baton Rouge police officer death". The Advocate. 24 September 2018.
- "WATCH: Accomplice in cop's killing taken back to jail". WBRZ-TV. 22 September 2017.
Further reading
External links
- Text of Brumfield v. Cain, 576 U.S. ___ (2015) is available from: Justia Oyez (oral argument audio) Supreme Court (slip opinion)