Montana v. Egelhoff

In July 1992, while camping out in the Yaak region of northwestern Montana to pick mushrooms, the defendant made friends with Roberta Pavola and John Christenson, who were doing the same.

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

He was charged with two counts of deliberate homicide.  His defense at trial was that his extreme intoxication rendered him physically incapable of committing the murders, and accounted for his inability to recall the events. The jury was not permitted to consider his intoxicated condition when deciding whether he met the mental element required for deliberate homicide. He was convicted, but the Supreme Court of Montana reversed, stating that the defendant had the right for the jury to consider “all relevant evidence” to rebut the State’s evidence on all elements of the offense charged, and that evidence of his voluntary intoxication was “clearly relevant” to the issue whether he acted knowingly and purposely.