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Law School Case Brief

Montana v. Egelhoff - 518 U.S. 37, 116 S. Ct. 2013 (1996)

Rule:

Preventing and dealing with crime is much more the business of the states than it is of the federal government, and the court should not lightly construe the constitution so as to intrude upon the administration of justice by the individual states. Among other things, it is normally within the power of the state to regulate procedures under which its laws are carried out, and its decision in this regard is not subject to proscription under the Due Process Clause, U.S. Const. amend. XIV, unless it offends some principle of justice so rooted in the traditions and conscience of our people as to be ranked as fundamental.

Facts:

Responding to reports of a possible drunk driver, officers of a Montana county sheriff's department discovered a car in a ditch along a highway. In the front seat of the car were two persons who had each been killed with a single gunshot to the head. In the rear of the car was the respondent, James Allen Egelhoff, who was yelling obscenities. Egelhoff’s handgun, with four loaded rounds and two empty casings, was found on the floor of the car and he was found to have gunshot residue on his hands. More than an hour later, Egelhoff’s blood-alcohol content was found to be .36 percent. He was charged with two counts of deliberate homicide, which was defined under Montana law as purposely or knowingly causing the death of another human being. At trial in a Montana state court, Egelhoff’s defense was that his extreme intoxication rendered him physically incapable of committing the murders and accounted for his inability to recall the events of the night that the murders were committed. Pursuant to a Montana statute, the jury was instructed that it could not consider Egelhoff’s intoxicated condition in determining the existence of a mental state which was an element of the offense. The jury found the individual guilty on both counts. On appeal, the Supreme Court of Montana, reversing, expressed the view that Egelhoff had a right, under the Due Process Clause of the Fourteenth Amendment, to present and have considered by the jury all relevant evidence of the offense charged. Furthermore, the state supreme court stated that evidence of Egelhoff’s voluntary intoxication was relevant to the issue whether he acted knowingly and purposely. Because the Montana statute prevented the jury from considering that evidence with regard to such issue, the individual had been denied due process in that Montana had been relieved of part of its burden to prove beyond a reasonable doubt every fact necessary to constitute the crime charged.

Issue:

Based on the circumstances of the case, were Egelhoff’s due process rights violated?

Answer:

No.

Conclusion:

On a writ of certiorari, the Supreme Court of the United States held that the proposition that the due process clause guaranteed the right to introduce all relevant evidence was indefensible, since an accused did not have an unfettered right to offer evidence that was incompetent, privileged, or otherwise inadmissible under standard rules of evidence. According to the Court, although the rule allowing a jury to consider evidence of an accused's voluntary intoxication where relevant to mens rea had gained considerable acceptance, such rule was of too recent vintage and had not received sufficiently uniform and permanent allegiance to qualify as a fundamental principle of justice for purposes of asserting a claim under the Due Process Clause, especially since such rule displaced a lengthy common-law tradition which still was supported by valid justifications. The Court reversed the judgment.

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