## Facts

- James Allen Egelhoff spent a day drinking with Roberta Pavola and John Christenson while camping in northwest Montana.
- Around midnight, police found Christenson’s station wagon in a ditch; Pavola and Christenson were dead from single gunshots to the head, and Egelhoff was in the back seat alive.
- Egelhoff’s blood alcohol content was measured at 0.36% more than an hour after discovery.
- A .38 handgun with two spent casings was found in the vehicle, and Egelhoff had gunshot residue on his hands.
- Montana charged Egelhoff with two counts of deliberate homicide, defined as purposely or knowingly causing another’s death.
- At trial, Egelhoff offered evidence of extreme voluntary intoxication to argue he lacked the required mental state and could not recall events.
- Under Mont. Code Ann. § 45-2-203, the jury was instructed that intoxication may not be considered in determining whether the defendant had a mental state that is an element of the offense.
- The jury convicted Egelhoff; the Montana Supreme Court reversed on due process grounds; the U.S. Supreme Court reversed the state high court.

## Issues

1. Whether the Due Process Clause of the Fourteenth Amendment forbids a state from instructing jurors not to consider voluntary intoxication when deciding whether the defendant acted purposely or knowingly.
2. Whether barring consideration of voluntary intoxication evidence impermissibly reduces the prosecution’s burden to prove every element beyond a reasonable doubt.

## Decision

- The Court held, 5–4, that Montana’s statute does not violate due process.
- A plurality reasoned that due process does not guarantee admission or consideration of all relevant defense evidence; evidentiary limits are unconstitutional only if they violate a fundamental principle of justice rooted in tradition.
- Looking to history, the plurality found no fundamental right to have voluntary intoxication considered to negate mens rea, emphasizing the common law’s strong rejection of intoxication as a basis for avoiding criminal responsibility.
- The plurality concluded the statute did not create an unconstitutional presumption or shift the burden of proof; it merely barred a category of evidence from bearing on the mental-state element.
- A concurrence in the judgment treated the statute as a permissible legislative definition of culpable mental states that makes self-induced intoxication irrelevant, while leaving the prosecution’s formal burden intact.

## Legal Principles

- Due process does not require a state to allow a defendant to have the jury consider voluntary intoxication evidence when determining whether the defendant possessed the mental state required for the charged offense.
- Restrictions on defense evidence violate due process only when they offend a fundamental principle of justice deeply rooted in the nation’s traditions and conscience.
- States have substantial authority to define the elements of crimes and to structure defenses, including by treating self-induced intoxication as irrelevant to proof of mens rea.
- A rule excluding consideration of certain evidence on mens rea does not violate due process merely because the evidence is relevant; it must also improperly shift burdens, create an unconstitutional presumption, or violate a fundamental principle of justice.

## Conclusion

The Court upheld Montana’s rule barring jurors from considering voluntary intoxication when deciding whether a defendant acted purposely or knowingly, concluding that the Fourteenth Amendment permits a state to define culpability in a way that makes self-induced intoxication irrelevant without unconstitutionally reducing the prosecution’s burden of proof.


Montana v. Egelhoff, 518 U.S. 37 (1996)