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  • Commentaries
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New Hampshire Case Commentaries

Rivas v. Ciecko (2026 N.H. 2) — Advance Notice Required for Missing-Witness Closing Arguments

Rivas v. Ciecko (2026 N.H. 2) — Advance Notice Required for Missing-Witness Closing Arguments

Date: Jan 29, 2026
Advance Notice Required Before Invoking the Missing-Witness Inference in Closing Argument Case: Rivas v. Ciecko, 2026 N.H. 2 (N.H. Jan. 27, 2026) Court: Supreme Court of New Hampshire (Gould, J.)...
Noise-Immunity for Shooting Ranges Under RSA 159-B:1 and :2 Requires Only Noise-Ordinance Compliance; “Began Operations” When Range Opened to the Public

Noise-Immunity for Shooting Ranges Under RSA 159-B:1 and :2 Requires Only Noise-Ordinance Compliance; “Began Operations” When Range Opened to the Public

Date: Jan 27, 2026
Noise-Immunity for Shooting Ranges Under RSA 159-B:1 and :2 Requires Only Noise-Ordinance Compliance; “Began Operations” When Range Opened to the Public Introduction In Martell v. Gold Bess Shooting...
In re Estate of Anna M. Hafey — Witness Initials Are Not “Signatures” Under RSA 551:2 Absent Intent; New Hampshire Declines Substantial Compliance

In re Estate of Anna M. Hafey — Witness Initials Are Not “Signatures” Under RSA 551:2 Absent Intent; New Hampshire Declines Substantial Compliance

Date: Jan 27, 2026
Witness Initials Are Not “Signatures” Under RSA 551:2 Absent Intent; New Hampshire Declines Substantial Compliance Case: In re Estate of Anna M. Hafey (N.H. Sup. Ct.) | Date: January 23, 2026 |...
Trial-Court Discretion to Limit Live Cross-Examination When Prior-Testimony Is Admitted for a Memory-Impaired Witness; Harmless-Error Review for Forensic Video Opinion; Work-Product Protection for Expert–Prosecutor Emails

Trial-Court Discretion to Limit Live Cross-Examination When Prior-Testimony Is Admitted for a Memory-Impaired Witness; Harmless-Error Review for Forensic Video Opinion; Work-Product Protection for Expert–Prosecutor Emails

Date: Jan 16, 2026
Trial-Court Discretion to Limit Live Cross-Examination When Prior-Testimony Is Admitted for a Memory-Impaired Witness; Harmless-Error Review for Forensic Video Opinion; Work-Product Protection for...
On-Call Permission Does Not Convert a Personal Errand into “Traveling Employee” Risk Under New Hampshire Workers’ Compensation Law

On-Call Permission Does Not Convert a Personal Errand into “Traveling Employee” Risk Under New Hampshire Workers’ Compensation Law

Date: Jan 9, 2026
On-Call Permission Does Not Convert a Personal Errand into “Traveling Employee” Risk Under New Hampshire Workers’ Compensation Law Case: Appeal of Michael Messina (Supreme Court of New Hampshire,...
Turner v. TD Bank: Conflicting Street Address and Book/Page in a Mortgage Creates an Ambiguity Requiring Extrinsic Evidence; Prior Quiet-Title Decree on Different Parcels Does Not Bar Later Litigation

Turner v. TD Bank: Conflicting Street Address and Book/Page in a Mortgage Creates an Ambiguity Requiring Extrinsic Evidence; Prior Quiet-Title Decree on Different Parcels Does Not Bar Later Litigation

Date: Jan 2, 2026
Turner v. TD Bank: Conflicting Street Address and Book/Page in a Mortgage Creates an Ambiguity Requiring Extrinsic Evidence; Prior Quiet-Title Decree on Different Parcels Does Not Bar Later...
Peregrine Interests LLC v. Todd: Member Withdrawal Is Not a “Transfer” Under the New Hampshire LLC Act Absent Express Contractual Limitation

Peregrine Interests LLC v. Todd: Member Withdrawal Is Not a “Transfer” Under the New Hampshire LLC Act Absent Express Contractual Limitation

Date: Dec 27, 2025
Peregrine Interests LLC v. Todd: Member Withdrawal Is Not a “Transfer” Under the New Hampshire LLC Act Absent Express Contractual Limitation I. Introduction In Peregrine Interests LLC & a. v. Todd,...
State v. Thet: Clarifying When Treating Physicians May Testify About a Sexual‑Assault Victim’s “Trauma History” Without Impermissible Credibility Bolstering

State v. Thet: Clarifying When Treating Physicians May Testify About a Sexual‑Assault Victim’s “Trauma History” Without Impermissible Credibility Bolstering

Date: Dec 27, 2025
State v. Thet: Clarifying When Treating Physicians May Testify About a Sexual‑Assault Victim’s “Trauma History” Without Impermissible Credibility Bolstering I. Introduction The Supreme Court of New...
No Expiration on Credibility: EES Inclusion of Former Officers and Old Misconduct under RSA 105:13-d

No Expiration on Credibility: EES Inclusion of Former Officers and Old Misconduct under RSA 105:13-d

Date: Dec 20, 2025
No Expiration on Credibility: EES Inclusion of Former Officers and Old Misconduct under RSA 105:13-d Introduction This commentary analyzes the New Hampshire Supreme Court’s order in John Doe v. New...
Material Prejudice and Proof of Coverage Gaps in Wireless Tower Zoning: Commentary on Whittier Communications, Inc. v. Town of Wakefield

Material Prejudice and Proof of Coverage Gaps in Wireless Tower Zoning: Commentary on Whittier Communications, Inc. v. Town of Wakefield

Date: Dec 16, 2025
Material Prejudice and Proof of Coverage Gaps in Wireless Tower Zoning: Commentary on Whittier Communications, Inc. v. Town of Wakefield I. Introduction This commentary analyzes the Supreme Court of...
Clarifying DCYF’s Duty to Inform Parents of Specific Abuse or Neglect Allegations Under RSA 169‑C:34, VI: Commentary on In re G.W.

Clarifying DCYF’s Duty to Inform Parents of Specific Abuse or Neglect Allegations Under RSA 169‑C:34, VI: Commentary on In re G.W.

Date: Dec 11, 2025
Clarifying DCYF’s Duty to Inform Parents of Specific Abuse or Neglect Allegations Under RSA 169‑C:34, VI: Commentary on In re G.W. I. Introduction The New Hampshire Supreme Court’s decision in In re...
Scrivener’s Errors, Pension Division, and Interim Orders in Divorce: Commentary on In the Matter of Warren & Jean Jackson (N.H. 2025)

Scrivener’s Errors, Pension Division, and Interim Orders in Divorce: Commentary on In the Matter of Warren & Jean Jackson (N.H. 2025)

Date: Nov 22, 2025
Scrivener’s Errors, Pension Division, and Interim Orders in Divorce: Commentary on In the Matter of Warren & Jean Jackson (N.H. 2025) I. Introduction The New Hampshire Supreme Court’s order in In the...
Reasonable Need, Not the Formula, Controls Term Alimony Under RSA 458:19-a: Commentary on In the Matter of Laurie Bondaz & Jean‑Pierre Bondaz

Reasonable Need, Not the Formula, Controls Term Alimony Under RSA 458:19-a: Commentary on In the Matter of Laurie Bondaz & Jean‑Pierre Bondaz

Date: Nov 22, 2025
Reasonable Need, Not the Statutory Formula, Controls Term Alimony Under RSA 458:19-a: Commentary on In the Matter of Laurie Bondaz & Jean‑Pierre Bondaz Commentary on the New Hampshire Supreme Court’s...
State v. Laforest: Defining the “Appropriate Court” Under New Hampshire’s Interstate Agreement on Detainers

State v. Laforest: Defining the “Appropriate Court” Under New Hampshire’s Interstate Agreement on Detainers

Date: Nov 22, 2025
State v. Laforest: Defining the “Appropriate Court” Under New Hampshire’s Interstate Agreement on Detainers I. Introduction In State v. Laforest, 2025 N.H. 49 (Nov. 21, 2025), the New Hampshire...
“Personnel Information” and Foreseeable Admissibility: Doe v. Concord Police Department and the Scope of New Hampshire’s Exculpatory Evidence Schedule

“Personnel Information” and Foreseeable Admissibility: Doe v. Concord Police Department and the Scope of New Hampshire’s Exculpatory Evidence Schedule

Date: Nov 20, 2025
“Personnel Information” and Foreseeable Admissibility: Doe v. Concord Police Department and the Scope of New Hampshire’s Exculpatory Evidence Schedule I. Introduction The Supreme Court of New...
UAGPPJA Is the Exclusive Basis for Adult Guardianship Jurisdiction in New Hampshire; “Home State” Is Determined by Physical Presence and a Respondent’s Objection Defeats Significant‑Connection Jurisdiction

UAGPPJA Is the Exclusive Basis for Adult Guardianship Jurisdiction in New Hampshire; “Home State” Is Determined by Physical Presence and a Respondent’s Objection Defeats Significant‑Connection Jurisdiction

Date: Nov 9, 2025
UAGPPJA Is the Exclusive Basis for Adult Guardianship Jurisdiction in New Hampshire; “Home State” Is Determined by Physical Presence and a Respondent’s Objection Defeats Significant‑Connection...
Stipulated Relocation Timelines Do Not Terminate UCCJEA Exclusive, Continuing Jurisdiction Absent RSA 458-A:13 Findings

Stipulated Relocation Timelines Do Not Terminate UCCJEA Exclusive, Continuing Jurisdiction Absent RSA 458-A:13 Findings

Date: Nov 1, 2025
Stipulated Relocation Timelines Do Not Terminate UCCJEA Exclusive, Continuing Jurisdiction Absent RSA 458-A:13 Findings Introduction In the Matter of Taylor Coyne and Ashley Blanchfield (N.H. Sup....
Statutory Right of Way and Directed Verdicts in Negligence: Commentary on Sheila Jenot v. Lyman Jenot, Jr. & a.

Statutory Right of Way and Directed Verdicts in Negligence: Commentary on Sheila Jenot v. Lyman Jenot, Jr. & a.

Date: Oct 29, 2025
Statutory Right of Way Does Not Justify a Directed Verdict in Negligence: Commentary on Sheila Jenot v. Lyman Jenot, Jr. & a. (N.H. 2025) 1. Introduction This New Hampshire Supreme Court order in...
Sending Districts Must Pay Tuition to Out‑of‑District Open Enrollment Schools Even Without Local Program Adoption (RSA 194‑D)

Sending Districts Must Pay Tuition to Out‑of‑District Open Enrollment Schools Even Without Local Program Adoption (RSA 194‑D)

Date: Oct 24, 2025
Sending Districts Must Pay Tuition to Out‑of‑District Open Enrollment Schools Even Without Local Program Adoption (RSA 194‑D) Introduction In Appeal of Pittsfield School District, 2025 N.H. 46 (Oct....
Ball v. Roman Catholic Bishop of Manchester: RSA 508:4-g Cannot Revive Pre-2020 Time-Barred Sexual-Assault Claims; Police-Power Balancing Limited to Contract-Impairment; Vested Limitations Defense Reaffirmed

Ball v. Roman Catholic Bishop of Manchester: RSA 508:4-g Cannot Revive Pre-2020 Time-Barred Sexual-Assault Claims; Police-Power Balancing Limited to Contract-Impairment; Vested Limitations Defense Reaffirmed

Date: Oct 16, 2025
Ball v. Roman Catholic Bishop of Manchester: RSA 508:4-g Cannot Revive Pre-2020 Time-Barred Sexual-Assault Claims; Police-Power Balancing Limited to Contract-Impairment; Vested Limitations Defense...
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