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Mentally Disabled Inmate Escapes Death Penalty Under 5th Cir. Ruling

By Jonathan R. Tung, Esq. on February 17, 2016 | Last updated on March 21, 2019

An intellectually disabled man successfully proved that he was intellectually disabled and thus ineligible for execution by the State of Louisiana. It's been a long voyage through the courts, but unless Louisiana would like to take this up to SCOTUS for a second time, it looks like Mr. Brumfield has escaped state administered death.

First-Degree Murder

The facts and procedure of the subject case are long and detailed; here's the thirty-second version:

The defendant-petitioner shot several rounds at a vehicle, killing someone inside. He at first denied his involvement, but later admitted on-tape his involvement in the killing. A jury found Brumfield of first-degree murder and he was sentenced. On appeal, Louisiana's Supreme Court affirmed the state court ruling. SCOTUS would later deny his request for cert.

Ineligible for Execution

In 2002, SCOTUS decided that executing the mentally disabled violated the Eighth Amendment prohibition against "cruel and unusual punishment" -- a finding, by the way, that Scalia regarded rather skeptically. Brumfield petition SCOTUS again for relief from execution; and contemporaneously filed a writ with Lousiana's high court asserting that it had screwed up by failing to hold an Atkins hearing. Remember, however, Atkins was decided after Brumfield was convicted and sentenced.

After much paper, the case made it to SCOTUS which ruled rather contentiously that a lower federal district court's refusal to grant Brumfield an evidentiary hearing on the point of his intellectual disability was unreasonable. Even though the case was remanded back to the Fifth Circuit, it was really, at that point, only a matter of time before the Brumfield would relieved of possible state administered death.

In the language of the Fifth Circuit: "[b]oth the state and Brumfield present plausible views of the evidence ... though Brumfield's [is stronger and more compelling]. Because the State has not demonstrated clear error on the part of the district, we AFFIRM the ruling of the district court that Brumfield is intellectually disabled and, accordingly, ineligible for execution."

Had it not been for the intervening Atkins case, it would be difficult to tell where Mr. Brumfield's case would be right now.

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