Montana v. Egelhoff case brief

Montana v. Egelhoff case brief summary
518 U.S. 37 (1996)

CASE SYNOPSIS

Defendant appealed his conviction for deliberate homicide on the ground that a jury instruction forbidding consideration of his voluntary intoxication in determining the existence of the requisite mental state under Mont. Code Ann. § 45-2-203 violated his Due Process rights. The Supreme Court of Montana reversed the conviction, and the State sought review.

CASE FACTS
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. Pursuant to Mont. Code Ann. § 45-2-203, the jury was instructed that it could not consider voluntary intoxication in determining the existence of the requisite mental state. The state supreme court reversed the conviction, holding that the rule denied defendant due process because the state did not have to prove beyond a reasonable doubt every element of the crime where the jury could not consider evidence relevant to the issue of mens rea.

DISCUSSION

• The court reversed, holding that 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. Constitutional amendment XIV, because it was too new, 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.

CONCLUSION
The court reversed the state supreme court's order reversing defendant's conviction for deliberate homicide because a jury instruction forbidding consideration of his voluntary intoxication in determining the existence of the requisite mental state was constitutionally permissible.


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