Montana v. Egelhoff

Supreme Court of the United States · 1996 · Evidence

EvidenceDue ProcessVoluntary IntoxicationMens ReaCriminal ProcedureDue Process Clausevoluntary intoxicationmens rea

Facts

After a day and evening of heavy drinking with two companions, respondent was found alive in the back of a car in a ditch, while the other two occupants were dead from single gunshots to the head. His blood-alcohol content measured .36 percent more than an hour later, his handgun was found on the car floor with two spent casings, and he had gunshot residue on his hands. He was charged with deliberate homicide, which Montana defines as purposely or knowingly causing death. At trial, he was allowed to use intoxication evidence to argue physical incapacity and lack of memory, but the jury was instructed under § 45-2-203 that it could not consider his intoxicated condition in determining whether the required mental state existed.

Issue

Whether the Due Process Clause is violated by a Montana statute providing that voluntary intoxication may not be taken into consideration in determining the existence of a mental state that is an element of a criminal offense. More specifically, the question was whether a defendant has a fundamental due process right to have the jury consider voluntary-intoxication evidence on mens rea.

Rule

The Due Process Clause does not give a criminal defendant an unfettered right to present all relevant evidence. A state evidentiary rule violates due process only if it offends a principle of justice so rooted in the traditions and conscience of the people as to be ranked as fundamental; the right to have a jury consider evidence of voluntary intoxication on mens rea is not such a fundamental principle.

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In Ohio, Nolan Price is charged with aggravated assault, which requires that he act knowingly. State law provides that a defendant's voluntary intoxication may not be considered in determining whether the required mental state existed, though the jury is still instructed that the prosecution must prove every element beyond a reasonable doubt. Nolan argues the statute is unconstitutional because his heavy drinking that night is highly relevant to whether he acted knowingly.

How should the court rule on Nolan's due process challenge?

Explanation. Under the lead opinion, a defendant has no unfettered due process right to present all relevant evidence. A state evidentiary restriction violates due process only if it offends a principle of justice so rooted in the traditions and conscience of the people as to be fundamental. The claimed right here—the right to have the jury consider voluntary intoxication in deciding mens rea—is not fundamental. So the statute may constitutionally exclude that category of evidence even if it is relevant.