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Frustration Over State Record in Mentally Ill Man's Death Penalty Case

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By Casey C. Sullivan, Esq. on April 02, 2015 3:55 PM

Several Supreme Court Justices expressed frustration with the record in the case of Brumfield v. Cain during oral arguments on Monday. At the heart of the case is whether Louisiana is bound by the Constitution to provide a separate hearing to decide whether someone convicted of murder is mentally disabled or not. The expansive record seemed to provide no clear guidance as to how the state's determination to not provide a hearing was made.

The Court ruled in Atkins v. Virginia, decided in 2002, that states may not execute mentally disabled individuals convicted of murder. But the decision also left it to the states to decide who fits into that category; now the Court must tackle with the adequacy of those determinations.

Mentally Disabled in Federal Court, but not in State

Kevan Brumfield was convicted in 1995 for the murder of a police officer and sentenced to death. He filed a post-conviction petition arguing that he could not be executed because he was mentally disabled. Brumfield was found to have an IQ as low as fifty-four, much lower than the median. The Louisiana state court refused to allow an Atkins hearing.

In a later habeas proceeding, a federal judge ruled that Brumfield was mentally disabled and enjoined the State from executing him. Under federal sentencing laws, a court must decline an application for a writ of habeas corpus where the claim has been adjudicated on the merits in state court, unless the adjudication was based on such an unreasonable determination of facts.

There was no such unreasonable determination in state court, the Fifth Circuit held on appeal and the federal district court should never have heard Brumfield's habeas petition. This left Brumfield in the position of being determined by federal court to be mentally disabled, but still scheduled for execution by the state.

Existing Record Frustrates Justices

At oral arguments, Justice Scalia stated that he had read none of the state court record, which is over twenty volumes long. Justices Roberts and Alito questioned whether they were simply reviewing disputed facts or answering a legal question.

Despite the many volumes in the state record, much of the oral arguments involved attempting to determine just how Louisiana had decided what evidence to consider in determining mental disability, or if any evidence must be offered at all, SCOTUSblog reports.

Should the Court chose simply to reject the case, Brumfield could be executed without ever having a full state hearing to determine his mental state.

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