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.
May a state restrict the elements of a defense in criminal prosecution, consistent with the Fourteenth Amendment Due Process Clause?
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.
Decisions
Decision: 5 votes for Montana, 4 vote(s) against Legal provision: Due Process
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Judgment of the Court by Justice Antonin Scalia
