New Hampshire Case Commentaries

State v. Hodgdon (2026 N.H. 6): Honest-but-False Accusations Generally Lack Probative Value for Rule 608(b) Impeachment

Date: Feb 13, 2026

State v. Hodgdon (2026 N.H. 6): Honest-but-False Accusations Generally Lack Probative Value for Rule 608(b) Impeachment Introduction In State v. Hodgdon, the New Hampshire Supreme Court affirmed...

State v. Owen (2026 N.H. 5) Commentary

Date: Feb 13, 2026

Rule 403 Limits “Post-Threat Security Measures” Evidence in Harassment-by-Threat Trials; Conditional Threats Turn on Objective Meaning (Not Specific Intent) Case: State v. Owen, 2026 N.H. 5 Court:...

Context-Driven Responsiveness Under RSA 91-A and Permissible Bad-Faith Findings to Support Remedies Without Naming Individual Officials

Date: Feb 13, 2026

Context-Driven Responsiveness Under RSA 91-A and Permissible Bad-Faith Findings to Support Remedies Without Naming Individual Officials Introduction In Laurie Ortolano v. City of Nashua & a. (N.H....

Perpetual IP Licenses and the One-Year Statute of Frauds: A License Is “Performed” When Granted (Absent an Express Covenant Not to Sue)

Date: Feb 7, 2026

Perpetual IP Licenses and the One-Year Statute of Frauds: A License Is “Performed” When Granted (Absent an Express Covenant Not to Sue) Case: Collision Commc'ns v. Nokia Solutions and Networks OY,...

State v. Price (2026 N.H. 3): Jury Must Decide “Deadly Force” Mens Rea and Must Be Unanimous as to the Particular Unprivileged Contact in Simple Assault

Date: Feb 1, 2026

State v. Price (2026 N.H. 3): Jury Must Decide “Deadly Force” Mens Rea and Must Be Unanimous as to the Particular Unprivileged Contact in Simple Assault I. Introduction In State v. Price, the New...

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

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

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

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

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

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

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

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

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

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.

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)

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

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

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

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...