518 U.S. 37, 116 S. Ct. 2013, 135 L. Ed. 2d 361 (1996)
On July 12, 1992, respondent James Egelhoff was camping in the Yaak region of northwestern Montana with Roberta Pavola and John Christenson to pick mushrooms.1 The three sold the mushrooms they had collected and spent the rest of the day and evening drinking in bars and at a private party in Troy, Montana.2 After leaving the party after 9 p.m. in Christenson's 1974 Ford Galaxy station wagon, the drinking continued, as Egelhoff was seen buying beer at 9:20 p.m. and recalled passing a bottle of Black Velvet with Christenson.3
Around midnight, officers of the Lincoln County sheriff's department discovered the station wagon stuck in a ditch along U.S. Highway 2.4 Pavola and Christenson were in the front seat, each dead from a single gunshot to the head.5 Egelhoff lay in the rear of the car, alive and yelling obscenities, with a blood-alcohol content of .36 percent measured over an hour later.6 His .38-caliber handgun lay on the floor near the brake pedal with four loaded rounds and two empty casings, and he had gunshot residue on his hands.7
Egelhoff was charged with two counts of deliberate homicide under Montana law requiring that he purposely or knowingly caused the deaths of another human being.8 At trial he claimed an unidentified fourth person must have committed the murders, that his extreme intoxication rendered him physically incapable of committing them, and that it accounted for his inability to recall the events.9 The trial court instructed the jury pursuant to Mont. Code Ann. § 45-2-203 that it could not consider respondent's intoxicated condition in determining the existence of a mental state which is an element of the offense.10 The jury found Egelhoff guilty on both counts and the court sentenced him to 84 years' imprisonment.11
The Supreme Court of Montana reversed the convictions.12 The United States Supreme Court granted certiorari.13
Whether Montana Code Annotated § 45-2-203, which provides that voluntary intoxication may not be taken into consideration in determining the existence of a mental state which is an element of a criminal offense, violates the Due Process Clause of the Fourteenth Amendment?14
The Due Process Clause of the Fourteenth Amendment does not prohibit states from excluding evidence of voluntary intoxication when determining whether a defendant possessed the requisite mental state for a crime.15 Such exclusion does not offend any principle of justice so rooted in the traditions and conscience of our people as to be ranked as fundamental.16
No. The Montana statute was applied in Egelhoff's trial to prevent the jury from considering his blood alcohol level of .36 percent in assessing whether he acted purposely or knowingly in causing the deaths of Pavola and Christenson.17 This application aligns with the common law tradition that voluntary intoxication does not excuse or negate mens rea, as reflected in historical authorities from Hale, Blackstone, and early American cases.18 The state retained the burden to prove the mental state beyond a reasonable doubt through other evidence, such as Egelhoff's handling of the handgun and the execution-style shootings.19 The exclusion merely rendered one category of evidence irrelevant without shifting any burden.20
The statute does not relieve the prosecution of proving every element.21 It simply deems intoxication evidence irrelevant to mens rea, consistent with Patterson v. New York and the absence of any fundamental right to introduce all relevant evidence.22
Montana Code Annotated § 45-2-203 does not violate the Due Process Clause of the Fourteenth Amendment.23
Related opinions on this issue
Justice O’Connor concurred in the judgment.24 She maintained that the statute violates due process by imposing a blanket exclusion on a category of relevant evidence that directly negates the mental-state element.25 This exclusion eases the prosecution’s burden without a valid justification beyond increasing the likelihood of conviction.26
She relied on Chambers v. Mississippi and Crane v. Kentucky to argue that due process requires a fair opportunity to present a defense.27 The statute prevents the defendant from raising an effective challenge to the mental state element that the state must prove beyond a reasonable doubt.28
Justice Ginsburg concurred in the judgment on the ground that the statute constitutes a legislative redefinition of the mens rea element rather than a mere evidentiary rule.29 She explained that by placing the provision in the criminal code’s general principles of liability section, Montana made voluntary intoxication logically irrelevant to proof of purpose or knowledge, rendering evidence of intoxication excludable without constitutional offense.30 This approach falls within the state’s wide latitude to define the elements of offenses.31
The statute embodies a legislative judgment regarding the circumstances under which individuals may be held criminally responsible for their actions.32
Joined by Justice Stevens
Justice Souter dissented.33 He agreed that a state may redefine mental elements to render intoxication irrelevant but concluded that the Montana Supreme Court had not interpreted the statute as effecting such a redefinition.34 He noted that the state failed to advance a valid justification for excluding relevant evidence under the Chambers line of cases, leaving the exclusion without adequate support once the court’s reading of state law was accepted as binding.35
The right to present a defense requires close examination of any competing interest said to justify limitation of relevant evidence.36
Joined by Justice Stevens
Justice Breyer joined Justice O’Connor’s dissent.37 He added that treating the statute as a redefinition would produce anomalous results. Guilt would turn on irrelevant external circumstances rather than state of mind.38
He observed that an intoxicated driver who unknowingly strikes a pedestrian might be convicted while one who sideswipes another car might not. This underscores why the legislature would not have intended such a roundabout redefinition.39 The statute turns guilt or innocence not upon state of mind but upon irrelevant external circumstances.40