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Montana v. Egelhoff

    Brief Fact Summary. 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.

    Synopsis of Rule of Law. Allowing evidence of voluntary intoxication is not a traditional well founded principle of American law that would constitute a violation of the Defendant’s 14th Amendment rights under the Constitution of the United States.

    Facts. Appellant was camping and made friends with others which he joined for a day of continuous drinking. The police discovered Appellant and the others in a car. The two others were dead by way of gunshots to the head. Appellant was witnessed in the back of the same car yelling obscenities and with an extremely high blood alcohol level. The jury was instructed that it could not take into account Appellant’s intoxication as a factor in determining the existence of the mental state. The jury found Appellant guilty and the Montana Supreme Court reversed stating that Appellant should be allowed to present evidence of voluntary intoxication.

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

    Held. 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.

    Although a rule allowing a jury to consider evidence of a defendant’s voluntary intoxication where relevant to mens rea has gained considerable acceptance, it is of too recent vintage and not fundamental to constitute the prohibition of allowing evidence of voluntary intoxication is not a violation of a defendant’s 14th Amendment rights.

    Concurrence. Justice Ginsburg concurred that the Montana statute was not unconstitutional regarding the presentment of voluntary intoxication evidence. However, Justice Ginsburg argued that the reason the court should uphold the prohibition on the introduction of voluntary intoxication evidence was that it was the state’s purpose to use the prohibition to further define the mental culpability required for the crime.

    Dissent. Justices O’Connor, Stevens, Souter and Breyer dissented. The dissent argued that due process demands that a criminal defendant be afforded a fair opportunity to defend against the State’s accusations. The dissent argued that key to this right is the opportunity to present evidence that would relate to the mental state required for the crime. The dissent argued that the plurality disregarded the Montana State Supreme Court’s ruling in error, as their interpretation of state law should be the final say.

    Discussion. The Court issued the opinion as a plurality The Court focused its analysis on the statute and its characterization as determinative on what evidence would be allowed. The statute specifically disallowed voluntary intoxication to be presented. The Montana Supreme Court ruled that the Due Process clause of the Constitution mandated that Appellant be allowed to present such evidence. The plurality further argued that presentment of such action was not a fundamental principle of justice and thus no violation of the Due Process clause had occurred. Furthermore, the State statute specifically forbid introduction of such evidence.


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