The United States Supreme Court decided on Thursday that a Louisiana man sentenced to death before the Court ruled that the Eighth Amendment prohibits execution of the intellectually disabled was entitled to an evidentiary hearing to determine whether he is intellectually disabled.
Kevan Brumfield was sentenced to death in 1995 for the killing of Baton Rouge police officer Betty Smothers. In 2002, the Supreme Court ruled in Atkins v. Virginia that intellectually disabled people cannot be executed.
Mr. Brumfield requested an opportunity to prove he was intellectually disabled in state court, but a state judge denied his claim without a hearing.
A federal judge ruled that it was unreasonable for the state court to deny Mr. Brumfield the opportunity to prove his claim. The court held a seven-day hearing and concluded that Mr. Brumfeld’s IQ and limited abilities to perform basic functions proved that he was disabled. The United States Court of Appeals for the Fifth Circuit, in New Orleans, reversed.
Justice Sonia Sotomayor wrote the majority opinion reversing the Fifth Circuit. Justices Anthony M. Kennedy, Ruth Bader Ginsburg, Stephen G. Breyer and Elena Kagan joined the majority opinion.
The Court reasoned that Mr. Brumfield’s IQ score of 75 “was squarely in the range of potential intellectual disability” and that the evidence introduced at his trial showed that he has adaptive deficits in learning and understanding and use of language. Mr. Brumfield was placed in special education classes at an early age, suspected of having a learning disability, and can barely read at a fourth-grade level. His low birth weight, commitment to mental health facilities at a young age, and officials’ administration of antipsychotic and sedative drugs to him at that time also point to significant adaptive deficits.
This evidence, the Court concluded, was enough “to raise a ‘reasonable doubt’ as to his intellectual disability to be entitled to an evidentiary hearing” in Louisiana. Because Mr. Brumfield cleared the procedural hurdles that require federal courts to defer to state court decisions, the Court held that he “was thus entitled to a hearing to show that he so lacked the capacity for self-determination that it would violate the Eighth Amendment to permit the State to impose the ‘law’s most severe sentence'” on him.