Brumfield v. Cain

In Brumfield v. Cain, 576 U.S. 135 S. Ct. 2269 , 192 L. Ed. 2d 356 (2015), a five member majority of the Supreme Court held that it was unreasonable for purposes of 28 U.S.C. 2254 for a state trial court to have concluded that a post-Atkins petitioner had not shown the reasonable doubt required by Louisiana law to merit an evidentiary hearing as to the petitioners possible intellectual disability when the record showed that the petitioner had a low birth weight, had been placed in special education classes at an early age and was suspected of having a learning disability, and had been committed to mental health facilities at a young age where he had been administered antipsychotic and sedative drugs. See id. at 135 S. Ct. at 2280- 81.