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In Matamoros v.
Stephens, F. District Court for the Southern District of Texas despite defense expert testimony alleging intellectual disability, and without expert testimony from the state. The court held that the Texas Court of Criminal Appeals was free to give more weight to nonscientific evidence than to scientific evidence and expert opinion.
The state trial court sentenced him to death. On direct appeal, the Texas Court of Criminal Appeals affirmed the conviction and sentence. After the Supreme Court held that it is unconstitutional to execute persons with intellectual disability in Atkins v. Virginia, U. Matamoros Adult Matamoros finder Matamoros his initial federal habeas petition, asserting that he was ineligible for the death penalty under Atkins because he had an intellectual disability.
The district court remanded the case to state court for reconsideration in light of Atkins. In the trial court held a hearing to consider Mr. Matamoros' Atkins claim. Matamoros offered expert testimony from psychologist Susana Rosin, who testified that Mr. Matamoros had an intellectual disability. She based her conclusions on interviews with Mr. Matamoros' letters, and Mr. Matamoros' test during his incarceration at TYC. Among other psychological standardized tests, Dr. Rosin administered the Wechsler Adult Intelligence Scale.
She found that Mr. Matamoros also presented evidence of intellectual disability based on tests that had been administered to him before the age of In contrast, the state offered testimony from psychologist George Denkowski that Mr. Matamoros did not have an intellectual disability. Denkowski administered psychological test measures and reviewed medical, disciplinary, and behavioral records.
Denkowski's conclusions were based on upward adjustments he made to Mr. Matamoros' plan for stealing cars, and his documented ability to formulate plans and to carry them through. The state argued that Mr. Matamoros' testimony was evidence of his ability to think logically, rationally, and thoughtfully. The state introduced Mr. Matamoros' denial that he had committed crimes of which he had been accused or convicted. Matamoros testified that he had pleaded guilty for an assault he had not actually committed, because he thought a jury was likely to believe the victim's word over his own.
The state argued that this explanation was evidence of Mr. Matamoros' having a logical understanding of how the criminal justice system works. The state also introduced records from Mr. Matamoros' time in state custody that stated that Mr.
Matamoros socialized, had leadership potential, and was proficient in his daily living skills. The trial court found that Mr. Matamoros had no intellectual disability under Atkinsand the Texas Court of Criminal Courts affirmed. However, in AprilDr. Matamoros then filed a motion in state court, requesting a rehearing on his Atkins claim in light of the settlement agreement regarding Dr. Denkowski'ssupported by affidavits from defense experts supporting his claim of intellectual disability.
Without acknowledging the defense affidavits or holding a new hearing, the state trial court again denied Mr. Matamoros' application, although the court stated in open court that it had discounted Dr. Denkowski's testimony. The Court of Criminal Appeals again denied Mr. Thus, the issue before the U. Court of Appeals for the Fifth Circuit was whether Mr.
Matamoros had shown, by clear and convincing evidence, that the Texas Court of Criminal Appeals had unreasonably determined that Mr. Matamoros did not exhibit adaptive behavior deficits that originated before the age of 18, and therefore he had no intellectual disability. The Fifth Circuit held that Mr. Matamoros did not show by clear and convincing evidence that the Texas Court of Criminal Appeals was unreasonable in concluding that Mr.
Matamoros did not meet his burden of proving that he had an intellectual disability. The court held that the Court of Criminal Appeals was free to weigh the observational evidence and its own interpretation of Mr. Matamoros' testimony more heavily than the scientific and expert reports presented by Mr.
In Texas, the standard for determining whether a person has an intellectual disability and thus is ineligible for the death penalty was established by the Texas Court of Criminal Appeals in Ex parte BrisenoS. The Briseno court placed the burden of proof on the defendant to show by the preponderance of the evidence that he had an intellectual disability. The Briseno court listed seven factors that courts may consider in their adaptive behavior analysis: 1 Did those who knew the person best during the developmental stage—his family, friends, teachers, employers, authorities—think he was mentally retarded at that time, and, if so, act in accordance with that determination?
Brisenopp 8—9. The U. Court of Appeals for the Fifth Circuit, Adult Matamoros finder Matamoros prior cases, has held that the Briseno factors are a constitutionally permissible application of Atkins and has denied federal habeas relief when the state court relies only on Briseno factors.
The Matamoros decision grants the courts wide latitude in determining intellectual disability. In this case, the court discounted the scientific evidence in the form of standardized IQ testing as well as expert opinions.
As the trier of fact, the court is free to make its own determination of fact based on its own analysis of the defendant's behavior. In Atkinsthe Supreme Court held that executing a person with an intellectual disability is unconstitutional, reasoning that persons with intellectual disabilities are at special risk of wrongful execution. However, the Court left states to devise procedures to determine what Adult Matamoros finder Matamoros an intellectual disability and therefore who should be excluded from capital punishment. This ruling led to consideration of the relationship between clinical and legal definitions of intellectual disability and questions of whether states should be compelled to rely on professional definitions or whether they can craft their own classifications.
Most states have defined intellectual disability according to the three-prong test from the Diagnostic and Statistical Manual of Mental Disorders, Fourth Edition DSM-IV : substantial limitations in intellectual functioning, substantial limitations in adaptive behavior, and evidence of the condition before the age of Several Adult Matamoros finder Matamoros, including Florida, Georgia, Mississippi, and Texas, have set their own standards. These standards have effectively excluded all but those with the most severe disabilities from the protections afforded by Atkins and have become the basis of appeal by death row inmates seeking relief under an Atkins claim.
Georgia set the standard of proof of intellectual disability at beyond a reasonable doubt. Therefore, those who do not have profound intellectual disability would be at risk of execution because of their inability to satisfy Georgia's standard of proof. In Hill v. HumphreyF. Court of Appeals for the Eleventh Circuit en banc majority reasoned that AEDPA demands deference to prior decisions of a state habeas court, and therefore the Georgia State Supreme Court's decision affirming the state's reasonable-doubt standard remains in place.
Florida set a bright-line standard IQ of 70, holding that any defendant with an IQ over 70 is eligible for the death penalty, regardless of the severity of his limitations and ignoring the scientific consensus that IQ scores represent a range of intellectual functioning, with standard deviation, rather than a definite determination of intellectual functioning. Florida's scheme was ultimately heard by the Supreme Court in Hall v.
Florida, S. The Court held that Florida's determination process was unconstitutional, as it created an intolerable risk of executing a citizen with intellectual disability. The Texas process of determining intellectual disability via the anecdotal Briseno criteria grants the courts wide latitude in determining intellectual disability.
Under those criteria, a person can be excluded from being categorized as having an intellectual disability based on nonscientific factors. As it stands, the Matamoros decision affirmed the court's freedom to make its own determination of fact based on its own analysis of the defendant's behavior, ignoring scientific evidence and expert opinions.
We do not capture any address. Other Legal Digest. Cortney Kohberger and Stephen Noffsinger.
Cortney Kohberger. Discussion The Matamoros decision grants the courts wide latitude in determining intellectual disability. Footnotes Disclosures of financial or other potential conflicts of interest: None. Next. Back to top. In this issue. Table of Contents Index by author. Download PDF. Article Alerts. Article. Your Personal Message. This question is for testing whether or not you are a human visitor and to prevent automated spam submissions. Citation Tools. Cortney KohbergerStephen Noffsinger. Share This Article: Copy.
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