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:

The defendant was convicted of deliberate homicide after police found him drunk in a vehicle next to his gun, with the two victims, each dead of gunshot wounds. Defendant 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, the individual'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 voluntary intoxication in determining the existence of the requisite mental state. The jury found the individual guilty on both counts. On appeal, the Supreme Court of Montana, reversing, expressed the view that (1) the individual had a right, under the due process clause of the Federal Constitution's Fourteenth Amendment, to present and have considered by the jury all relevant evidence of the offense charged, The state supreme court was under the impression that the evidence of the individual's voluntary intoxication was relevant to the issue on whether the individual acted knowingly and purposely, and since  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:

Does a state statute preventing jury consideration of evidence per se violate the due process clause? 

ANSWER:

No.

CONCLUSION:

Five members of the Court held that the Montana statute did not violate the due process clause. The Court asserted that the defendant did not uphold his burden of showing that the rule allowing consideration of intoxication on the question of intent was a fundamental principle under U.S. Const. amend. XIV, because it was too new and had not received sufficiently uniform and permanent allegiance, and displaced a lengthy and justified common law tradition. The Court noted the validity of the statute in deterring irresponsible behavior while drunk and upheld the principle that the introduction of relevant evidence was subject to limitation by the state for a "valid" reason.

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