Montana v. Egelhoff

518 U.S. 37 (1996)

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Nature of the Case

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Facts

Egelhoff (D) was picking mushrooms with Roberta Pavola and John Christenson. They sold the mushrooms and spent the rest of the day drinking. The drinking binge continued until officers of the sheriff's department discovered their station wagon stuck in a ditch with Pavola and Christenson each dead from a single gunshot wound to the head. In the rear of the car was D, alive and yelling obscenities. His blood alcohol level was .36 percent even one hour later. On the floor of the car near D lay D's .38 caliber handgun with four loaded rounds and two empty casings. D had gunshot residue on his hands. D's defense at trial was that an unidentified fourth person committed the murders; his own intoxication had rendered him physically incapable of committing them. The jury was instructed that it could not consider D's condition with respect to intoxication. D was found guilty and appealed. The Supreme Court of Montana reversed. The court reasoned (1) that D “had a due process right to present and have considered by the jury all relevant evidence to rebut the State's evidence on all elements of the offense charged, and (2) that evidence of D's voluntary intoxication was “clearly . . . relevant to the issue of whether [respondent] acted knowingly and purposely.” The Supreme Court granted certiorari.