Brumfield v. Cain, Warden, No. 12-30256 (5th Cir. 2014)
Annotate this CaseThe district court granted habeas relief in favor of petitioner, finding that he is mentally retarded and therefore ineligible for execution based on Atkins v. Virginia. The state appealed the district court's imposition of a permanent injunction enjoining the State from executing petitioner. The district court concluded that the state court was required to provide petitioner with the funds necessary to develop his claims. The court concluded that the district court erred in its determination that the state court decision was not entitled to deference under 28 U.S.C. 2254(d)(1) where there was no Supreme Court decision that has held that prisoners asserting Atkins claims were entitled to expert funds to make out a prima facie case. Similarly, the state court's judgment did not violate 28 U.S.C. 2254(d)(2) where petitioner did not contend that he presented a prima facie showing of mental retardation before the state court and, therefore, waived his claim. Accordingly, the court reversed the district court's grant of habeas relief.
The court issued a subsequent related opinion or order on January 20, 2014.
The court issued a subsequent related opinion or order on February 28, 2014.
The court issued a subsequent related opinion or order on December 16, 2015.
The court issued a subsequent related opinion or order on February 10, 2016.
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