context: The pleading standard a defendant must meet to demonstrate he is entitled to an Atkins hearing is a low one.
citation_a.signal: see
citation_a.parenthetical: finding Lousiana standard that a defendant must raise a "reasonable doubt" as to their intellectual disability before being entitled to an Atkins hearing consistent with Atkins
citation_a.sentence: See Brumfield v. Cain, — U.S. -, 135 S. Ct. 2269, 192 L.Ed.2d 356 (2015) (finding Lousiana standard that a defendant must raise a “reasonable doubt” as to their intellectual disability before being entitled to an Atkins hearing consistent with Atkins); Simpson, 490 F.3d at 1035. “There is no question the allegations in [Davis’] petition are as adequate as Simpson’s pleading threshold where the petitioner ‘alleged that he is mentally retarded as Atkins defines that condition’ in order to obtain an evidentiary hearing on his mental retardation claim.”
citation_b.signal: see also
citation_b.identifier: 615 F.3d 959, 963-64
citation_b.parenthetical: finding that the defendant's petition "satisfied the pleading standard of Simpson and Sasser I, by expressly incorporating" evidence of trouble in school, an IQ score of 70, difficulty with visual motor and expressive and receptive language skills, and diagnoses of ADHD and antisocial personality disorder
citation_b.sentence: Sasser I, 553 F.3d at 1126 (quoting Simpson, 490 F.3d at 1035); see also Jackson v. Norris, 615 F.3d 959, 963-64 (8th Cir. 2010) (finding that the defendant’s petition “satisfied the pleading standard of Simpson and Sasser I, by expressly incorporating” evidence of trouble in school, an IQ score of 70, difficulty with visual motor and expressive and receptive language skills, and diagnoses of ADHD and antisocial personality disorder).