Montana v. Egelhoff

Case Date: 03/20/1996
Docket No: none

Facts of the Case 

James Allen Egelhoff was tried in Montana courts for two counts of homicide. Egelhoff claimed that extreme intoxication rendered him physically incapable of committing or recalling the crimes. Montana law did not allow Egelhoff's intoxicated condition to be considered. Subsequently, Egelhoff was found guilty. The Supreme Court of Montana reversed the decision. It held Egelhoff had a due process right to present all relevant evidence. Moreover, it held that Montana law's denial of such a presentation relieved the state from part of its burden of proof needed to convict Egelhoff.

Question 

May a state restrict the elements of a defense in criminal prosecution, consistent with the Fourteenth Amendment Due Process Clause?

Argument Montana v. Egelhoff - Oral ArgumentFull Transcript Text  Download MP3 Conclusion  Decision: 5 votes for Montana, 4 vote(s) against Legal provision: Due Process

Yes. The Court could not reach a majority on the reasons for its decision. Justice Antonin Scalia, who announced the judgment of the Court, declared that defendants do not have an absolute constitutional right to present all relevant evidence in their defense.