KOEHLER v. ENGLE

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Case Basics
Docket No. 
83-1
Petitioner 
Theodore Koehler
Respondent 
Tilden N. Engle
Opinion 
Advocates
(on behalf of the petitioner)
(on behalf of the respondent)
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Facts of the Case 

Tilden N. Engle was an employee of a plant owned and operated by the Chrysler Corporation. Chrysler dismissed him on December 4th, 1972. Engle suffered from alcoholism, and he drank heavily following his dismissal. On December 7th, he consumed four anti-anxiety Librium pills and large quantities of whiskey. That day, he returned to the plant and told his nephew Chrysler employee Renus Engle, that he was going to kill someone. Renus Engle testified that the Tilden had a nervous pitch to his voice and tears in his eyes. According to Renus Engle, the respondent had been drinking but was not drunk.

Engle went to the office of Donald Ambrose, a clerk, and asked for Regis Lantzy, whom Engle believed was responsible for his termination. Ambrose said that Lantzy was not present, and later testified that Engle looked strange, as if something was troubling him. A short time later, Engle found Lantzy in the plant. Engle shot Lantzy with a pistol in front of several workers. Lantzy tried to flee, and Engle shot him several more times. He stood over the body briefly, then returned to Ambrose’s office and surrendered to a security guard. The guard smelled alcohol on Engle’s breath, but officers who arrived later on the scene did not detect the odor of alcohol. On December 8th, Engle gave a statement to the police. He admitted to purposefully shooting and killing Lantzy, albeit under the influence of alcohol.

On trial for murder in July, 1973, Engle’s sole defense was temporary insanity due to the effects of alcohol, Librium, and a dissociative reaction, a temporary mental disorder often accompanied by memory loss. He stated that he remembered nothing between drinking the morning of December 7th and the moment he awoke in jail. He did not remember making a statement to the police.

The trial judge instructed the jury that malice --a necessary element for conviction-- is “implied from any deliberate and cruel act against another person.” Regarding Engle’s use of a pistol, the trial judge instructed the jury that “a person is presumed to intend the natural consequences of his acts.” He also instructed the jury to consider the number and location of Lantzy’s wounds when considering the issue of malice. Engle was convicted of murder and sentenced to life in prison without parole. He appealed, arguing the jury instructions constituted reversible error.

A unanimous U.S. Court of Appeals, Sixth Circuit, reversed. It rejected Koehler’s argument that Engle’s failure to make a timely objection prevented him from raising the issue of jury instruction on appeal, noting that Michigan courts do not enforce a contemporaneous objection rule. The court held that the jury could have inferred from the instructions that the burden of proving lack of malice and intent lay with Engle. He also argued that the jury could have presumed from the use of a deadly weapon and the number and location of Lantzy’s wounds that these facts alone constituted proof beyond a reasonable doubt of Engle’s malice and intent. He held that the error was not harmless beyond a reasonable doubt, pointing to conflicting evidence about Engle’s state of mind at the time of the shooting.

Question 

Did the jury instructions on malice and intent create an improper presumption of guilt in Engle’s trial for first-degree murder? If so, was this a harmless error?

Conclusion 
Decision: 4 votes for Engle, 4 vote(s) against
Legal provision:

Yes and no. In a per curiam opinion delivered by an equally divided Court, the Supreme Court affirmed the Sixth Circuit’s judgment without further comment.

Justice Marshall took no part in the decision of the case.

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KOEHLER v. ENGLE. The Oyez Project at IIT Chicago-Kent College of Law. 27 November 2014. <http://www.oyez.org/cases/1980-1989/1983/1983_83_1>.
KOEHLER v. ENGLE, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1980-1989/1983/1983_83_1 (last visited November 27, 2014).
"KOEHLER v. ENGLE," The Oyez Project at IIT Chicago-Kent College of Law, accessed November 27, 2014, http://www.oyez.org/cases/1980-1989/1983/1983_83_1.