Montana v. Egelhoff Case Brief

Why is the case important?

Appellant was convicted of premeditated murder. Appellant argued that he should have been allowed to present evidence of voluntary intoxication to show that he did not commit premeditated murder.

Facts of the case

James Allen Egelhoff was tried in Montana courts for two counts of homicide. Egelhoff claimed that extreme intoxication rendered him physically incapable of committing or recalling the crimes. Montana law did not allow Egelhoff’s intoxicated condition to be considered. Subsequently, Egelhoff was found guilty. The Supreme Court of Montana reversed the decision. It held Egelhoff had a due process right to present all relevant evidence. Moreover, it held that Montana law’s denial of such a presentation relieved the state from part of its burden of proof needed to convict Egelhoff.

Question

Whether voluntary intoxication may negate a requisite mental state for the crime of homicide.

Answer

The Montana Supreme Court’s decision is reversed.
Although voluntary intoxication cannot negate a mental state, it can be shown to the jury to help them assess whether a defendant acted in premeditation or if the murder was done only in the heat of passion.

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.”

  • Case Brief: 1996
  • Petitioner: Montana
  • Respondent: Egelhoff
  • Decided by: Rehnquist Court

Citation: 518 US 37 (1996)
Argued: Mar 20, 1996
Decided: Jun 13, 1996