Montana v. Egelhoff
Annotate this Case
518 U.S. 37 (1996)
OCTOBER TERM, 1995
MONTANA v. EGELHOFF
CERTIORARI TO THE SUPREME COURT OF MONTANA No. 95-566. Argued March 20, 1996-Decided June 13, 1996
On trial for two counts of deliberate homicide-defined by Montana law as "purposely" or "knowingly" causing another's death-respondent claimed that extreme intoxication had rendered him physically incapable of committing the murders and accounted for his inability to recall the events of the night in question. After being instructed, pursuant to Mont. Code Ann. § 45-2-203, that respondent's "intoxicated condition" could not be considered "in determining the existence of a mental state which is an element of the offense," the jury found respondent guilty. In reversing, the Supreme Court of Montana reasoned that respondent had a right, under the Due Process Clause, to present and have the jury consider "all relevant evidence" to rebut the State's evidence on all elements of the offense charged, and that evidence of his voluntary intoxication was "clearly relevant" to the issue whether he acted knowingly and purposely. Because § 45-2-203 prevented the jury from considering that evidence, the court concluded that the State had been relieved of part of its burden of proof and that respondent had therefore been denied due process.
Held: The judgment is reversed.
272 Mont. 114, 900 P. 2d 260, reversed.
JUSTICE SCALIA, joined by THE CHIEF JUSTICE, JUSTICE KENNEDY, and JUSTICE THOMAS, concluded that § 45-2-203 does not violate the Due Process Clause. Pp.41-56.
(a) The State Supreme Court's proposition that the Due Process Clause guarantees the right to introduce all relevant evidence is indefensible. See, e. g., Taylor v. Illinois, 484 U. S. 400, 410; Fed. Rule Evid. 403; Fed. Rule Evid. 802. The Clause does place limits upon restriction of the right to introduce evidence, but only where the restriction "offends some principle of justice so rooted in the traditions and conscience of our people as to be ranked as fundamental." See Patterson v. New York, 432 U. S. 197,201-202. Respondent has failed to meet the heavy burden of establishing that a defendant's right to have a jury consider voluntary intoxication evidence in determining whether he possesses the requisite mental state is a "fundamental principle of justice." The primary guide in making such a determination, historical practice, gives respondent little support. It was firmly established at common law that a defendant's voluntary intoxication provided neither an "excuse"
nor a "justification" for his crimes; the common law's stern rejection of inebriation as a defense must be understood as also precluding a defendant from arguing that, because of his intoxication, he could not have possessed the mens rea necessary to commit the crime. The justifications for this common-law rule persist to this day, and have only been strengthened by modern research. Although a rule allowing a jury to consider evidence of a defendant's voluntary intoxication where relevant to mens rea has gained considerable acceptance since the 19th century, it is of too recent vintage, and has not received sufficiently uniform and permanent allegiance to qualify as fundamental, especially since it displaces a lengthy common-law tradition which remains supported by valid justifications. Pp. 41-51.
(b) None of this Court's cases on which the Supreme Court of Montana's conclusion purportedly rested undermines the principle that a State can limit the introduction of relevant evidence for a "valid" reason, as Montana has. The Due Process Clause does not bar States from making changes in their criminal law that have the effect of making it easier for the prosecution to obtain convictions. See McMillan v. Pennsylvania, 477 U. S. 79, 89, n. 5. Pp. 51-56.
JUSTICE GINSBURG concluded that § 45-2-203 should not be categorized as simply an evidentiary rule. Rather, § 45-2-203 embodies a legislative judgment regarding the circumstances under which individuals may be held criminally responsible for their actions. The provision judges equally culpable a person who commits an act stone sober, and one who engages in the same conduct after voluntary intoxication has reduced the actor's capacity for self-control. Comprehended as a measure redefining mens rea, § 45-2-203 encounters no constitutional shoal. States have broad authority to define the elements of criminal offenses in light of evolving perceptions of the extent to which moral culpability should be a prerequisite to conviction of a crime. Defining mens rea to eliminate the exculpatory value of voluntary intoxication does not offend a fundamental principle of justice, given the lengthy common-law tradition, and the adherence of a significant minority of the States to that position today. Pp. 56-61.
SCALIA, J., announced the judgment of the Court and delivered an opinion, in which REHNQUIST, C. J., and KENNEDY and THOMAS, JJ., joined. GINSBURG, J., filed an opinion concurring in the judgment, post, p. 56. O'CONNOR, J., filed a dissenting opinion, in which STEVENS, SOUTER, and BREYER, JJ., joined, post, p. 61. SOUTER, J., filed a dissenting opinion, post, p. 73. BREYER, J., filed a dissenting opinion, in which STEVENS, J., joined, post, p. 79.
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