Whether the Eleventh Circuit's failure to limit its review of a reasoned state-court decision under 28 U.S.C. § 2254(d) to the specific reasons given by the state court contravenes this Court's precedent

QUESTION PRESENTED In Wilson v. Sellers, this Court affirmed, as it has “time and again,” that when evaluating a reasoned state-court decision under 28 U.S.C. § 2254(d), the federal habeas court “simply reviews the specific reasons given by the state court and defers to those reasons if they are reasonable.” 138 S. Ct. 1188, 1192 (2018); see also, e.g., Brumfield v. Cain, 576 U.S. 305, 313 (2015). Nearly every circuit court has followed this Court’s instruction. The Eleventh Circuit, breaking from its sister circuits, has repeatedly strayed beyond the reasons given by the state court, invoking its own reasons to conclude that § 2254(d) bars relief. Here, the Eleventh Circuit’s methodology resulted in the denial of a hearing on intellectual disability under Atkins v. Virginia, 536 U.S. 304 (2002), and risks the execution of a person with intellectual disability. This case thus presents the following question: Whether the Eleventh Circuit’s failure to limit its review of a reasoned state-court decision under 28 U.S.C. § 2254(d) to the specific reasons given by the state court contravenes this Court’s precedent in Wilson v. Sellers, 138 S. Ct. 1188 (2018), and Brumfield v. Cain, 576 U.S. 305 (2015). i LIST OF RELATED DECISIONS Trial and Direct Appeal State v. Jenkins, No. CC-89-68 (St. Clair Cnty. Cir. Ct. Apr. 10, 1991) Jenkins v. State, No. CR-90-1044 (Ala. Crim. App. Feb. 28, 1992), reh’g denied (Apr. 17, 1992) Ex parte Jenkins, No. 1911144 (Ala. May 28, 1993), reh’g denied (Oct. 8, 1993) Jenkins v. Alabama, No. 93-7423 (S. Ct. Mar. 28, 1994) State Post-Conviction Proceedings Jenkins v. State, No. CC-89-68.60 (St. Clair Cnty. Cir. Ct. Dec. 31, 1997) Jenkins v. State, No. CR-97-0864 (Ala. Crim. App. Feb. 27, 2004), reh’g denied (May 21, 2004) Ex parte Jenkins, No. 1031318 (Ala. Apr. 8, 2005) Jenkins v. State, No. CR-97-0864 (Ala. Crim. App. Nov. 23, 2005), reh’g denied (Apr. 14, 2006), cert. denied, No. 1050972 (Ala. May 18, 2007) Jenkins v. Alabama, No. 07-7215 (S. Ct. Jan. 22, 2008) Successor State Post-Conviction Proceedings Jenkins v. State, No. CC-89-68.61 (St. Clair Cnty. Cir. Ct. Nov. 25, 2008) Jenkins v. State, No. CR-08-0490 (Ala. Crim. App. Aug. 26, 2011) Ex parte Jenkins, No. 1101410 (Ala. Sept. 21, 2012) Jenkins v. Alabama, No. 12-7860 (S. Ct. Mar. 25, 2013) Federal Habeas Proceedings Jenkins v. Allen, No. (N.D. Ala. Aug. 31, 2016) Jenkins v. Commissioner, Alabama Department of Corrections, No. 17-12524 (11th Cir. June 29, 2020), reh’g denied (Aug. 26, 2020) ii