stating that “[t]he accused does not have an unfettered right to offer evidence that is ... inadmissible under standard rules of evidence” and citing Montana Rule of Evidence 403, which is identical to HRE Rule 403, as among the “number of familiar and unquestionably constitutional evidentiary rules” that “authorize the exclusion of relevant evidence” (internal quotation marks, citation, and brackets omitted)
How later courts described this case
- stating that “[t]he accused does not have an unfettered right to offer evidence that is ... inadmissible under standard rules of evidence” and citing Montana Rule of Evidence 403, which is identical to HRE Rule 403, as among the “number of familiar and unquestionably constitutional evidentiary rules” that “authorize the exclusion of relevant evidence” (internal quotation marks, citation, and brackets omitted)
- explaining that a prior holding that exclusion of certain evidence violated constitutional rights “rested not on a theory that all ‘competent, Court of Appeals of Indiana | Memorandum Decision 18A-CR-1953 | July 9, 2019 Page 13 of 23 reliable evidence’ must be admitted, but rather on the ground that the . . . sole rationale for the exclusion . . . was wrong”
- explaining that the Court’s holding in Crane, which concluded that the exclusion of certain evidence violated the defendant’s constitutional rights, “rested not on a theory that all ‘competent, reliable evidence’ must be admitted, but rather on the ground that the Supreme Court of Kentucky’s sole rationale for the exclusion . . . was wrong.”
- explaining that “Chambers was an exercise in highly case-specific error correction,” and that “the holding of Chambers — if 'one can be discerned from such a fact-intensive case— is ... that erroneous evidentiary rulings can, in combination, rise to the level of a due process violation”
Written by the judges who cited it.
The opinion
Justice Breyer,
with whom Justice Stevens joins, dissenting.
I join Justice O’Connor’s dissent. As the dissent says, and as Justice Souter agrees, the Montana Supreme Court did not understand Montana’s statute to have redefined the mental element of deliberate homicide. In my view, however, this circumstance is not simply happenstance or a technical matter that deprives us of the power to uphold that statute. To have read the statute differently — to treat it as if it had redefined the mental element — would produce anomalous results. A statute that makes voluntary intoxication the legal equivalent of purpose or knowledge but only where external circumstances would establish purpose or knowledge in the absence of intoxication, see ante, at 58 (Ginsburg, J., concurring), is a statute that turns guilt or innocence not upon state of mind, but upon irrelevant external circumstances. An intoxicated driver stopped at an intersection who unknowingly accelerated into a pedestrian would likely be found guilty, for a jury unaware of intoxication would likely infer knowledge or purpose. An identically intoxicated driver racing along a highway who unknowingly sideswiped another car would likely be found innocent, for a jury unaware of intoxication would likely infer negligence. Why would a legislature want to write a statute that *80 draws such a distinction, upon which a sentence of life imprisonment, or death, may turn? If the legislature wanted to equate voluntary intoxication, knowledge, and purpose, why would it not write a statute that plainly says so, instead of doing so in a roundabout manner that would affect, in dramatically different ways, those whose minds, deeds, and consequences seem identical? I would reserve the question of whether or not such a hypothetical statute might exceed constitutional limits. Cf. McMillan v. Pennsylvania, 477 U. S. 79, 85-86 (1986); Patterson v. New York, 432 U. S. 197, 210 (1977); Mullaney v. Wilbur, 421 U. S. 684, 698-699 (1975).