Montana v. Egelhoff

Facts

In July of 1992, Egelhoff was out camping and picking mushrooms when he met Roberta Pavola and John Christenson. They became friends. On July 12, they spent the evening drinking in bars and at a private party together. They left the party around 9pm and continued to binge drink.

At about midnight the same night, officers responded to a report of a possible drunk driver and discovered Christenson’s car stuck in a ditch. In the front seat, Pavola and Christenson were both found dead from a gunshot. Egelhoff was alive in the backseat, yelling obscenities. On the floor of the car, near the brake pedal, was Egelhoff’s gun. His blood-alcohol content measured .36% one hour later and he had gunshot residue on his hands.

The jury was not permitted to consider his intoxicated condition in determining the existence of the required mental state of deliberate homicide. He was convicted of two counts. The Supreme Court of Montana reversed, holding that Egelhoff’s intoxication was relevant to the issue of whether he acted knowingly and purposely.