State v. Coffin: Familial Sexual-Assault Provision Does Not Extend to Stepsiblings Unrelated by Blood

1. Introduction

In State v. Coffin, the Supreme Court of New Hampshire held that RSA 632-A:2, IV, which criminalizes sexual penetration of a person under eighteen within specified familial relationships, does not apply to stepsiblings who are unrelated by blood. The statute expressly covers brothers and sisters “of the whole or half blood.” Its additional reference to “stepchildren” does not enlarge that category to include stepsiblings.

The defendant, Jason Coffin, and the complainant shared no biological parent. Coffin’s biological father married the complainant’s biological mother, after which the two saw one another on various weekends, holidays, and family occasions. The State alleged that Coffin assaulted the complainant several times over approximately two years.

The central issue was not whether stepsiblings can have a meaningful family relationship, or whether misconduct within that relationship may violate other criminal provisions. It was whether the particular relationship alleged satisfied the language of RSA 632-A:2, IV. The court answered that narrower question through the statute’s ordinary meaning and structure, declining to extend its coverage on the basis of a broader protective purpose.

2. Background and Procedural History

A grand jury indicted Coffin on five counts of aggravated felonious sexual assault under RSA 632-A:2, IV. The State also charged six related misdemeanor sexual-assault counts. According to the record described in the opinion, those misdemeanor charges likewise required a qualifying relationship under RSA 632-A:2, IV, through RSA 632-A:4, I(a).

During trial, the complainant testified about the family’s structure and his relationship to Coffin. Following a break in that testimony, Coffin moved to dismiss all charges, arguing that the State could not establish the familial relationship required by the statute.

The Superior Court agreed with Coffin’s statutory interpretation and initially granted dismissal. At the State’s request, however, it instead declared a mistrial without prejudice and transferred the statutory question for interlocutory review under Supreme Court Rule 8.

The Supreme Court therefore reviewed a legal ruling made before final resolution of the prosecution. Its decision affirmed the trial court’s interpretation and remanded for further proceedings; it did not resolve the truth of the alleged assaults or determine liability under other statutory provisions.

3. Statutory Framework and Summary of the Decision

RSA 632-A:2 defines several forms of aggravated felonious sexual assault. These offenses generally involve an aggravating circumstance, such as force, threats, deception, a pattern of abuse, or a particular relationship between the actor and the complainant. Under paragraph IV, the specified familial relationship supplies the relevant aggravating factor.

The provision states:

A person is guilty of [AFSA] when such person engages in sexual penetration as defined in RSA 632-A:1, V with another person under 18 years of age whom such person knows to be his or her ancestor, descendant, brother or sister of the whole or half blood, uncle, aunt, nephew, or niece. The relationships referred to herein include blood relationships without regard to legitimacy, stepchildren, and relationships of parent and child by adoption.

The parties agreed that Coffin and the complainant were not brothers “of the whole or half blood.” The State nevertheless argued that the second sentence’s inclusion of “stepchildren” brought their relationship within the provision.

The court rejected that interpretation. Its principal conclusions were:

• The sibling category expressly requires a blood relationship. Stepsiblings sharing no biological parent do not satisfy that language.
• “Stepchildren” identifies a parent-stepchild relationship. It does not ordinarily describe the relationship between the respective children of spouses.
• General protective purposes cannot add an omitted relationship. A familial connection capable of involving trust is not sufficient unless it falls within the enacted provision.
• The statute is unambiguous on the question presented. The court therefore did not need to resolve the State’s challenge to the trial court’s reliance on marriage-license law.

4. Analysis of the Court’s Legal Reasoning

A. Independent Review and the Primacy of Statutory Language

The court reviewed the statutory interpretation de novo, independently examining the legal question rather than deferring to the trial court’s conclusion. It began with familiar interpretive principles: statutory words ordinarily receive their plain meaning; every word should be given effect where possible; related provisions should be read together; and courts may not add language the legislature omitted.

The phrase “brother or sister of the whole or half blood” was decisive. It does not refer generally to all persons socially or legally regarded as siblings. Instead, it specifies a biological relationship. Because Coffin and the complainant shared no biological parent, they did not fall within that category.

B. Why “Stepchildren” Does Not Mean “Stepsiblings”

The State’s position depended on treating “stepchildren” as extending beyond the relationship between a stepparent and a spouse’s child. The court found no textual basis for that extension.

Because the criminal code did not define the term, the court consulted the Oxford English Dictionary, which defines a “stepchild” as “[a] child of a person’s spouse or partner by a previous marriage or relationship.” That definition identifies a child in relation to a stepparent. It does not identify one child’s relationship to another child.

The distinction matters because kinship terms describe particular relationships. Two people may each be a stepchild within a blended family, but that does not make their relationship to each other a parent-stepchild relationship. The statutory term therefore cannot be transferred from one relationship to another simply because both arise from the same marriage.

The court also read the word in context. The second sentence addresses blood relationships regardless of legitimacy, stepchildren, and adoptive parent-child relationships. It expands or clarifies coverage in specified ways; it does not establish a general rule covering every relationship created by marriage. The court understood the reference to “stepchildren” as including parent-stepchild assaults, not as incorporating all forms of step-kinship.

C. Protective Purpose Does Not Replace Enumerated Categories

The State argued that RSA 632-A:2 addresses relationships of trust capable of exploitation and that paragraph IV protects minors whose ability to consent may be compromised by the nature of family relationships. These arguments identified a possible policy rationale for broader coverage, but the court held that they could not overcome the provision’s actual wording.

The surrounding statutory scheme reinforced that conclusion. Other provisions expressly address therapeutic relationships, victims with disabilities, educational settings, shared households, and certain relationships by blood or affinity. Their existence demonstrates that the legislature has used particular language to identify different aggravating circumstances.

The court did not deny that the relationship between Coffin and the complainant was familial. It held that the relationship was not among those included in paragraph IV. Thus, the provision’s protective purpose operates through its specified categories, not through an unrestricted judicial assessment of whether a relationship presents comparable risks.

D. The Court Did Not Decide the Marriage-License Issue

The State also challenged the trial court’s placement of “significant weight” on the possibility that Coffin and the complainant could have obtained a marriage license under RSA 5-C:46. The Supreme Court declined to address that argument because the sexual-assault statute’s language was independently clear.

Accordingly, the decision does not establish that eligibility to marry determines whether a familial relationship falls within RSA 632-A:2, IV. The holding rests on the criminal provision itself, not on a necessary correspondence between marriage restrictions and sexual-offense definitions.

E. The Legislature Retains Responsibility for Broader Coverage

The court concluded by observing that the legislature could amend the statute, within constitutional bounds, if it disagreed with the interpretation. This observation reflects the allocation of institutional responsibility underlying the decision: courts interpret the enacted categories, while lawmakers decide whether additional relationships should be included.

The opinion did not rely on legislative history or invoke the rule of lenity to resolve competing plausible meanings. It instead treated the relevant language as unambiguous.

5. Precedents Cited and Their Influence

The cited decisions principally supplied interpretive methods, procedural guidance, and examples. The opinion did not identify a prior decision directly resolving whether paragraph IV covers stepsiblings unrelated by blood.

State v. Zarella

State v. Zarella, 177 N.H. 328, 332 (2025), 2025 N.H. 20, ¶3, supplied the approach to the factual record on interlocutory review. The court accepted the case statement and facts presented in the interlocutory appeal statement, consulting the record as necessary. Its relevance was procedural rather than substantive: it explained the source of the facts used to answer the transferred legal question.

State v. Cormiea

State v. Cormiea, 177 N.H. 654, 656 (2025), 2025 N.H. 50, ¶7, provided the main interpretive framework. The court relied on it for de novo review, ordinary meaning, giving effect to statutory words, avoiding judicial additions, and harmonizing a provision with the larger statutory scheme.

Those principles directly shaped the outcome. They required attention to “whole or half blood,” prevented the addition of “stepsiblings,” and supported reading “stepchildren” in its surrounding context rather than as an isolated invitation to expand coverage.

State v. Hill

State v. Hill, 172 N.H. 711, 714 (2019), established that plain and unambiguous language eliminates the need to seek further indications of legislative intent. It supported both the court’s text-centered analysis and its decision not to address the dispute over the marriage-license statute.

State v. Keenan

State v. Keenan, 171 N.H. 557, 563 (2018), supported consulting common usage and dictionaries when a statute leaves a term undefined. It provided the methodological basis for examining the ordinary meaning of “stepchild,” a central step in rejecting the State’s interpretation.

State v. Munroe; State v. Carter; State v. Oropallo

The court cited State v. Munroe, 161 N.H. 618, 620–21 (2011); State v. Carter, 140 N.H. 1, 2, 5 (1995); and State v. Oropallo, 128 N.H. 305, 306 (1986), as examples of parent-stepchild assaults.

Their role was illustrative: they showed the recognizable category of conduct addressed by including “stepchildren.” The opinion did not analyze their holdings as resolving stepsibling coverage, and they should not be treated as precedents for that distinct question.

State v. Levier

State v. Levier, 177 N.H. 757, 769 (2026), 2026 N.H. 7, ¶30, supported the concluding observation that the legislature may amend a statute if it disagrees with the court’s interpretation, subject to constitutional limits. It reinforced the distinction between construing existing criminal legislation and expanding its substantive reach.

6. Impact and Limits of the Decision

A. Consequences for Charging and Proof

Prosecutions under RSA 632-A:2, IV must establish a relationship actually covered by the provision. Describing the parties as family members, showing recurring family contact, or establishing a potentially exploitable relationship of trust cannot substitute for that statutory requirement.

The decision also affects the misdemeanor charges described in this record because they depended on the same qualifying relationship. Nevertheless, the Supreme Court’s disposition was an affirmance of the legal ruling and a remand, not a final adjudication of every possible charge or procedural issue.

B. No General Exemption for Sexual Misconduct Between Stepsiblings

The holding is limited to RSA 632-A:2, IV and the absence of the required relationship. Other sexual-offense provisions may apply when their separate elements are satisfied. The opinion itself identifies provisions concerning force, threats, particular age groups, shared households, and relationships by affinity, but it does not decide their applicability to Coffin’s alleged conduct.

C. Guidance for Interpreting Family-Relationship Provisions

The decision demonstrates that an express inclusion of one nonbiological relationship does not automatically include every analogous family relationship. Future litigants invoking this reasoning will need to examine the precise kinship terms, qualifications, and surrounding statutory language.

The court did not comprehensively resolve the status of every adoptive or extended step-family relationship. Its holding addresses stepsiblings unrelated by blood, and broader conclusions would require additional statutory analysis.

D. Potential Legislative Response

If lawmakers wish to include stepsiblings within paragraph IV, the opinion indicates that clearer statutory language is needed. Any such amendment would raise drafting choices concerning the relationships covered and their boundaries. Those choices remain legislative questions rather than matters resolved by this decision.

7. Complex Concepts Simplified

Interlocutory appeal

An appeal addressing a legal issue before the underlying case has reached its ordinary final conclusion. Here, the transferred issue concerned statutory coverage.

De novo review

Independent appellate review of a legal question, without deference to the trial court’s legal interpretation.

Aggravating factor

A circumstance making an offense more serious under the statute. In paragraph IV, the specified family relationship is the relevant aggravating circumstance.

Whole blood and half blood

Whole-blood siblings share both biological parents; half-blood siblings share one. Stepsiblings unrelated by blood share neither biological parent.

Affinity

A relationship through marriage rather than biological descent. The court noted that another provision expressly uses this term, unlike paragraph IV’s sibling language.

Blood relationships without regard to legitimacy

Biological relationships count regardless of whether a child’s parents were married. The phrase does not turn a nonbiological relationship into a biological one.

Mistrial without prejudice

A trial ended without a final verdict, with the order not itself barring further prosecution. The opinion did not resolve separate issues concerning any future proceedings.

Plain-meaning interpretation

Reading statutory words according to their ordinary meaning in context, rather than adding coverage based on a perceived broader purpose.

8. Conclusion

State v. Coffin establishes that RSA 632-A:2, IV does not cover stepsiblings unrelated by blood. “Stepchildren” extends the provision to parent-stepchild relationships; it does not erase the express blood requirement governing siblings.

The decision’s broader significance lies in its insistence on precise statutory boundaries. Protective purposes and analogous family dynamics cannot supply an omitted criminal category. Any expansion to cover stepsiblings under this provision must come from the legislature.