Dunn v. Reeves

Matthew Reeves, an Alabama death-row inmate convicted of the 1996 murder of Willie Johnson, filed a federal habeas corpus petition asserting intellectual disability as a bar to execution under Atkins v. Virginia. He requested funds under 18 U.S.C. § 3599(f) to retain an expert to support the claim. The district court denied funding, finding it not reasonably necessary because state postconviction proceedings had already included expert evaluation and the state court's rejection of the claim was entitled to AEDPA deference. The Eleventh Circuit granted mandamus, ordering the district court to provide the funds. The Supreme Court reversed in a per curiam opinion on July 2, 2021, holding that the district court had not abused its discretion. It stressed that Reeves had failed to demonstrate that the state court's denial of his intellectual-disability claim was unreasonable on the existing record and that federal courts must apply AEDPA deference.

The Supreme Court reversed the Eleventh Circuit, holding that the district court did not abuse its discretion, and remanded for further proceedings consistent with the opinion.

Whether the district court abused its discretion in denying Reeves's motion for expert funding under 18 U.S.C. § 3599(f), given AEDPA deference to the state court's rejection of his intellectual-disability claim.

The decision limits the availability of federally funded expert assistance in capital habeas litigation and reinforces the barriers federal habeas petitioners face in developing new evidence after state court adjudication.