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Montana v Egelhoff
S. Ct. US, 1996
Author:- Sam
Biers
Voluntary Intoxication
Relevant Facts: Defendant was convicted of deliberate homicide when police found him drunk in the back seat of a vehicle next to his gun, with the two victims in the front seat, each dead of gunshot wounds. The three had been drinking and partying all night, after picking mushrooms.
Legal Issue(s): Whether the Montana statute, that voluntary intoxication may not be taken into consideration in determining the existence of a mental state which is an element of a offense, denies due process of law?
Court’s Holding: Yes
Procedure: Df appealed his conviction in the S Ct of Mont for deliberate homicide b/c he alleged that a jury instruction forbidding consideration of his voluntary intoxication in determining the existence of the requisite mental state violated his due process rights, U.S. Const. amend. XIV. The judgment is reversed by state s. ct. S. Ct. reversed.
Law or Rule(s): NEW- Intoxication can be considered in determining whether a df was capable of forming the specific intent to commit the crime charged. OLD - not excuse or justification
Court Rationale: The historical record states voluntary intoxication is not an excuse nor justification for the commission of a crime. The burden remains on the df to show that the new common law rule that intoxication may be considered on the question of intent, under the Fourteenth Amendment that it is a fundamental right. Not so. One fifth of the States never adopted or abandoned it. States have kept the common law rule - Disallowing voluntary intox. Has teheffect of increasing the punishment for all unlawful acts committed in that state, and deters drunkenness; ensures that those who are incapable of controlling violent impulses while intox. go to prison; society’s moral perception that one who voluntarily impairs is responsible for consequences.
Plaintiff’s Argument: Df voluntarily consumed the intoxicants and purposely caused the death of another.
Defendant’s Argument: Df’s extreme intoxication rendered him physically incapable of the acts.