## Facts

- Kevan Brumfield was convicted in Louisiana of murdering an off-duty police officer and was sentenced to death.
- After *Atkins v. Virginia* barred executing persons with intellectual disability, Brumfield amended his state postconviction petition to assert an *Atkins* claim.
- Brumfield requested an evidentiary hearing and funding, relying on mitigation evidence from sentencing, including an IQ score of 75, a fourth-grade reading level, childhood psychiatric treatment and medications, identification of a learning disability, and placement in special education.
- The state trial court denied a hearing and funding, concluding Brumfield failed to show intellectual disability; the Louisiana Supreme Court denied review without reasons.
- In federal habeas under 28 U.S.C. § 2254, the district court funded development of the claim, received new expert and documentary evidence, and granted relief barring execution.
- The Fifth Circuit reversed, holding AEDPA deference applied and the state court’s threshold denial was not an unreasonable factual determination.
- The Supreme Court granted certiorari to review whether the state court’s refusal to allow an *Atkins* hearing rested on an unreasonable determination of facts under § 2254(d)(2) and what that meant for federal merits review.

## Issues

1. Whether the Louisiana trial court’s denial of an *Atkins* evidentiary hearing was “based on an unreasonable determination of the facts” in light of the state-court record, under 28 U.S.C. § 2254(d)(2).
2. If § 2254(d)(2) is satisfied, whether federal habeas courts may consider the *Atkins* claim on the merits, including evidence developed in federal proceedings.

## Decision

- The Supreme Court vacated the Fifth Circuit’s judgment and remanded.
- The Court held that the state court’s refusal to grant an *Atkins* hearing was based on unreasonable factual determinations under § 2254(d)(2).
- The Court concluded that, because § 2254(d)(2) was met, federal courts were not barred by AEDPA from reaching the merits of Brumfield’s *Atkins* claim and considering developed evidence.

## Legal Principles

- AEDPA deference under 28 U.S.C. § 2254(d)(2) does not protect state-court decisions resting on unreasonable determinations of fact when measured against the state-court record.
- A state court acts unreasonably when it treats an IQ score (including one above 70) as foreclosing subaverage intellectual functioning without accounting for accepted measurement error and *Atkins*’ rejection of rigid cutoffs.
- A state court acts unreasonably when it finds no evidence of adaptive deficits despite record evidence that could support significant limitations (e.g., special education placement, low academic functioning, childhood psychiatric history, learning disability).
- When a petitioner satisfies § 2254(d)(2), federal habeas courts may proceed to adjudicate the constitutional claim on the merits and are not confined to the state court’s threshold fact-finding.

## Conclusion

The Court held that Louisiana unreasonably denied Brumfield even an evidentiary hearing on his *Atkins* claim, so AEDPA did not bar federal merits review; the Fifth Circuit’s contrary ruling was vacated and the case remanded for further proceedings consistent with that holding.


Brumfield v. Cain, 576 U.S. 305 (2015)