Detailed Case Study: Analysis of Brumfield v. Cain in Business Law

This case study analyzes the legal case of Brumfield v. Cain, which involves a defendant with intellectual disabilities facing the death penalty. The case explores the application of Atkins v. Virginia, which prohibits the execution of individuals with intellectual disabilities. The analysis delves into the key facts, including the defendant's low IQ, history of learning disabilities, and involvement in a murder. The central issue revolves around whether it is just to impose the death penalty on someone with intellectual limitations. The Supreme Court's ruling, which emphasizes the need for an evidentiary hearing and considers the defendant's intellectual impairments, is examined. The study assesses the court's reasoning, which highlights moral considerations and the importance of evaluating adaptive skills and neuropsychological disorders. The critical analysis points out the state court's failure to properly assess the defendant's mental state and the impact of the Supreme Court's decision to accept the application. The case underscores the importance of considering intellectual disabilities in legal proceedings, especially when dealing with capital punishment.

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1 Name of the Case - Brumfield v. Cain, 576
2 Name of the Court – The United States Supreme Court
3 Case Citation- U.S 28 U.S.C. § 2254(d)(2)(2015)
5 Key facts- In this case Kevan Brumfield had been sentenced to death for the murder of an off
duty officer Smothers. Brumfield had been accompanied by another individual who assisted him
in the murder of officer Smothers while she had been escorting grocery manager to the bank. It
can be stated that officer Smothers had a son named Warrick Dunn, who had later become
successful as a sportsman.
It had later been realized that Brumfield had very low I.Q. His level of I.Q was that of a fourth
grade student and he had been treated at psychiatric hospitals for having learning disability as a
child. He also had to attend special education classes. In this case the lower court had rejected
the decision of Atkins v Virginia and had sentenced him to death due to the murder of officer
Smothers.
4 Issues – The issue that had been discussed in this case was whether it was just to give death
penalty to a person who had a learning disability and was mentally challenged according to the
judgment of the remarkable case Atkins v Virginia.
5 Rule- In this case the Supreme court had held that an evidentiary hearing was required as the
defendant’s attorney had presented the facts which provided evidence of the following facts:
 Below average level of intelligence of the defendant
 Impairment of several adaptable skills which were significant in nature
 Evidence of neuropsychological disorder

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In this case the trial court had dismissed the case of the defendant without holding any hearing or
conducting any investigations or granting funds for the purpose of conducting investigations. In
this case the trial court had rejected the principle of the case Atkins v. Virginia, 536 U.S. 304
(2002). In the aforementioned case it had been held by the Supreme Court of the United States
by a majority of 6-3 that people with intellectual disabilities should not be executed. The
rationale behind this decision is that executing people who have intellectual disabilities is in
violation of the ban on cruel and unusual punishments as provided in eighth amendment.
However the supreme court of the United States held that the defendant had satisfied the
requirement of §2254(d)(2) and was therefore entitled to have his claim of the decision of
Atkin’s case. It can be stated that the court emphasized on the point that the result of the I.Q test
of Brumfield was 75 and therefore he could be passed as an individual who suffered intellectual
disability. Further it can be said that there was sufficient records which had been presented to the
state courts containing evidence to suggest that the defendant met the criteria for adaptive
impairment. The court assessed the low intelligence of Brumfield as he had been placed in
special education classes at a very early age and had been suspected of having learning difficulty.
Thus he experienced substantial limitation of daily functions in three out of six major areas of
activities of life.
Decision:
This case is based on the punishment process of an intellectually disable person. It has
been found from the facts of the case that the applicant of this case was charged under murder,
the State Court of Australia held him guilty, and the court was pleased to pass death sentence for
him. However, it has been observed that the convict is intellectually disabled and the learned
court had failed to analyze the condition of the applicant. Further, it has been observed that the

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applicant had submitted many documents in the support of his plea. Further, he had made a plea
that his matter should be considered as the case of Atkins v Virginia 536 US 304. However, the
court has failed to consider all the documents and delivered the capital punishment. Aggrieved
by such judgment, the applicant is seeking for federal habeas relief. The US Supreme Court has
observed that the applicant has fulfilled the requirements of section 2254 (d) (2) and therefore,
the rule stated in Atkins’ case would be applicable in this case and the punishment of the
applicant could be reconsidered.
Reasoning:
There are certain people who are suffering from mental incapacity and the imposition of
law in their case should be based on moral consideration. According to the court of law, in case a
person is proved to be an intellectually disabled, an evidentiary hearing to this effect is required.
It is a formal examination where the evidences are administered on oath and the parties can take
defense against specific charges. This fair opportunity is given to the disable person. Further, it
has been held in the case of Atkins v Virginia that the intellectual disability of a person can be
determined by way of three tests that have been established in the case of State v.
Williams, 2001–1650 (La. 11/1/02), 831. According to this case, the sub-average intelligence of a
person should be taken into consideration. This can be identified by the IQ test. Further, adaptive
skill of the individual and neuro-psychological disorder should be analyzed by the court. If a
person can proved the fact that he is intellectually disable, the court should have to consider his
condition and can minimized his punishment. If any court has failed to consider the same, the
aggrieved party can make a plea under federal habeas corpus for the interference of Federal
Supreme Court in that matter. The documents submitted by the applicant have proved his
disabilities and the Supreme Court accepts his application accordingly.

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Critical analysis:
In this case, it has been observed that the State court was failed to consider all the
documents submitted by the applicant. According to the Supreme Court, the observation made
by the state court reflects unreasonableness and the State court has failed to examine the mental
status of the applicant properly. Further, the State court has failed to provide any evidentiary
hearing to him. Proper interpretation of Atkins’ case has also not been done here. The
testimonies of the applicant have attracted the provision of section 2254 (d) (2) and therefore, the
Supreme Court has pleased to accept the application.

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Reference List:
Brumfield v. Cain, 576 .S 28 U.S.C. § 2254(d)(2)
Atkins v Virginia 536 US 304
State v. Williams, 2001–1650 (La. 11/1/02), 831