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 Supreme Court resolved a practical but legally significant question under the Interstate Agreement on Detainers (IAD), codified at RSA 606-A:1 et seq.: when does a prisoner's request for final disposition of New Hampshire charges validly trigger the 180-day speedy-trial clock?

The Court held that, under New Hampshire’s implementing statutes, a prisoner satisfies the IAD’s requirement to serve the “appropriate court” when he causes his request to be delivered to any superior court within the prosecuting officer’s jurisdiction—here, any Hillsborough County superior court division (North or South). The Court rejected the State’s argument that the IAD clock never started because the request was sent to the “wrong” judicial district of the superior court (Hillsborough-South) rather than the district where the indictments were pending (Hillsborough-North).

This decision establishes an important precedent: in New Hampshire, the phrase “appropriate court” in Article III(a) of the IAD, as defined by RSA 606-A:2, does not mean “the particular division or judicial district where the charges are pending.” Instead, service on the county’s superior court—so long as it is within the prosecuting officer’s jurisdiction—is legally sufficient to start the 180-day period. Failures by courts or prosecutors to forward or act on the paperwork do not delay that clock.

II. Summary of the Opinion

The State appealed from a Superior Court order (Messer, J.) dismissing two indictments against defendant Raymond Laforest with prejudice. Laforest, serving a sentence in Pennsylvania, invoked Article III of the IAD by requesting final disposition of three pending New Hampshire charges, all based in Hillsborough County (two in Hillsborough-North, one in Hillsborough-South).

The Pennsylvania prison forwarded his IAD request to:

• The Hillsborough County Attorney’s Office in Nashua; and
• The Hillsborough County Superior Court in Nashua (Hillsborough-South).

Both the prosecutor and Hillsborough-South received the request by December 26, 2023. Hillsborough-South took no action and did not forward the request to Hillsborough-North. The State did not complete its own IAD paperwork until May 2024 and did not seek an extension of the 180-day period until June 3, 2024—less than three weeks before the asserted June 22, 2024 deadline.

The Superior Court initially granted a 120-day extension but, on reconsideration, concluded the State lacked good cause, and later dismissed the two Hillsborough-North indictments with prejudice for violating the 180‑day limit. The State’s sole argument on appeal was that the clock never began to run because the defendant had not served his request on the “appropriate court” (Hillsborough-North).

The New Hampshire Supreme Court:

• Held the State’s argument preserved for appeal, despite the absence of a hearing transcript, because the trial court’s orders showed it had addressed the precise issue.
• Interpreted RSA 606-A:2’s definition of “appropriate court” to include the superior court as an institution, not a specific district within that court.
• Concluded that service on Hillsborough-South, coupled with service on the Hillsborough County Attorney, satisfied Article III(a), thus triggering the 180-day period on December 26, 2023.
• Emphasized Article III(d): the defendant’s request operated as a request for disposition of all New Hampshire detainers directed to the Hillsborough County Attorney, including those pending in Hillsborough-North.
• Held that, because the State failed to bring Laforest to trial within 180 days and lacked good cause for an extension, dismissal with prejudice was mandatory.

The Court affirmed the dismissal of the indictments.

III. Factual and Procedural Background

A. The Underlying Charges and Detainers

In 2022, grand juries in Manchester (Hillsborough-North) indicted Laforest on two charges that are the subject of this appeal. Separately, there was at least one additional charge pending in Nashua (Hillsborough-South), also giving rise to a New Hampshire detainer.

By 2023, Laforest was serving a sentence in a Pennsylvania correctional facility on an unrelated matter. New Hampshire lodged detainers against him there. A “detainer” is:

a request filed by a criminal justice agency with the institution in which a prisoner is incarcerated, asking that the prisoner be held for the agency, or that the agency be advised when the prisoner's release is imminent. Fex v. Michigan, 507 U.S. 43, 44 (1993).

B. The IAD Request

On December 21, 2023, Laforest executed an Article III request for final disposition under the IAD. His paperwork:

• Explicitly listed three Hillsborough County charges supported by detainers: two in Hillsborough-North, one in Hillsborough-South.
• Was transmitted by the Pennsylvania facility superintendent to:
  • The Hillsborough County Attorney’s Office, and
  • The Superior Court in Nashua (Hillsborough-South),
  by certified mail.

Both the County Attorney and Hillsborough-South received the request around December 26, 2023.

C. Inaction and Delay

After receiving the request:

• Hillsborough-South:
  • Took no action on the request.
  • Did not docket it, even as to the charge pending in that court.
  • Did not forward the request to Hillsborough-North for the two Manchester indictments.
• The State:
  • Conceded it received the paperwork by late December 2023.
  • Did not complete its IAD paperwork until May 2024.
  • Did not seek an Article III continuance (extension) until June 3, 2024, when the alleged 180-day period was about to expire on June 22, 2024.

D. Extension, Reconsideration, and Dismissal

On June 3, 2024, the State moved to extend the 180-day limit, arguing:

• It was “unaware the Court was served the paperwork.”
• There had been “unforeseen delays and lack of docketing.”

The defendant objected, contending that:

• Service was sufficient under the IAD, and
• The State could not show “good cause” to justify an extension.

Initially, the Superior Court:

• Found that “adequate service was made under the statute,” because the request had been sent to the prosecuting authority and a superior court in Hillsborough County.
• Granted the State a 120-day extension, declining to place all blame for the delay on either party.

Upon the defendant’s motion to reconsider, the court reversed itself, finding:

• The State had not demonstrated good cause.
• The State had “allowed the paperwork to languish” until it was essentially too late to bring Laforest to New Hampshire for trial within 180 days.

The defendant then moved to dismiss. The court:

• Granted the motion, dismissing the two Hillsborough-North indictments with prejudice under RSA 606-A:1, Art. V(c).
• Rejected the State’s motion to reconsider (and its supplement) as untimely and unpersuasive.

The State appealed, focusing narrowly on whether Laforest’s request had been served on the “appropriate court” under the IAD.

IV. Legal Framework

A. The Interstate Agreement on Detainers

The IAD is:

a compact entered into by 48 States, the United States, and the District of Columbia to establish procedures for resolution of one State's outstanding charges against a prisoner of another State. State v. Bjorkman, 171 N.H. 531, 535 (2018).

In New Hampshire, the IAD is codified at RSA 606-A:1 (2001). Because Congress has consented to this compact, it is federal law subject to federal construction.¹

Article I of the IAD states its core purpose:

to encourage the expeditious and orderly disposition of such charges and determination of the proper status of any and all detainers based on untried indictments, informations or complaints. RSA 606-A:1, Art. I.

B. Article III(a): The 180-Day Rule

Article III(a) provides, in relevant part:

Whenever a person has entered upon a term of imprisonment in a penal or correctional institution of a party state, and whenever during the continuance of the term of imprisonment there is pending in any other party state any untried indictment, information or complaint on the basis of which a detainer has been lodged against the prisoner, he shall be brought to trial within 180 days after he shall have caused to be delivered to the prosecuting officer and the appropriate court of the prosecuting officer's jurisdiction written notice of the place of his imprisonment and his request for a final disposition to be made of the indictment, information or complaint . . . .

Thus, three elements are central:

1. An untried New Hampshire charge with a detainer lodged against the prisoner.
2. The prisoner causes written notice and a request for final disposition to be delivered to:
   • the prosecuting officer, and
   • the “appropriate court” of that officer’s jurisdiction.
3. Within 180 days of such delivery, the State must bring the prisoner to trial, absent a proper continuance, waiver, or inability to stand trial.

Failure to comply has a mandatory consequence. Article V(c) provides that if the charge “is not brought to trial within the period provided in Article III,” the court:

shall enter an order dismissing the same with prejudice, and any detainer based thereon shall cease to be of any force or effect. RSA 606-A:1, Art. V(c) (emphasis added).

The “with prejudice” language means the State cannot reinstate or refile those specific charges; they are permanently barred.

C. New Hampshire’s Definition of “Appropriate Court”

The IAD itself uses the term “appropriate court” but does not define it uniformly for all jurisdictions. New Hampshire has enacted a separate definitional statute:

The phrase “appropriate court” as used in the agreement on detainers shall, with reference to the courts of this state, mean the municipal court, the district court or the superior court. RSA 606-A:2 (2001).

The interpretive question in Laforest is whether “the superior court” refers to the superior court as a unified institution in the county, or whether it implies the specific division or judicial district where the charges are pending.

D. Article III(d): One Request Covers All Detainers

Article III(d) provides:

Any request for final disposition made by a prisoner pursuant to paragraph (a) hereof shall operate as a request for final disposition of all untried indictments, informations or complaints on the basis of which detainers have been lodged against the prisoner from the state to whose prosecuting official the request for final disposition is specifically directed. RSA 606-A:1, Art. III(d) (emphases added).

Thus, a single request to the Hillsborough County Attorney, where multiple New Hampshire detainers exist, is deemed a request for final disposition of all such New Hampshire detainers, regardless of the particular court or division in which each charge is pending.

V. Issues Before the Court

The Supreme Court identified and resolved two principal issues:

1. Preservation: Did the State preserve for appellate review its argument that service on Hillsborough-South was inadequate, notwithstanding the absence of a hearing transcript?
2. Merits: Under RSA 606-A:1 (Art. III(a)) and RSA 606-A:2, does serving an IAD request on the Hillsborough County Attorney and the Hillsborough-South Superior Court qualify as service on the “prosecuting officer and the appropriate court of the prosecuting officer’s jurisdiction,” thereby triggering the 180-day clock for charges pending in Hillsborough-North?

If the answer to the second question was “yes,” then the 180-day period began around December 26, 2023. Because the State did not bring Laforest to trial within that time and lacked good cause for an extension, dismissal with prejudice would be required by Article V(c).

VI. Court’s Holding and Reasoning

A. Preservation and Record Adequacy

The defendant argued that the State had not preserved its IAD-service argument and had failed to provide an adequate record by omitting the transcript of the extension hearing. The Court reaffirmed two principles:

• Issues generally must be raised before the trial court to be preserved. State v. Batista-Salva, 171 N.H. 818, 822 (2019).
• The appellant (here, the State) bears the burden of showing that the same argument was presented below.

Although the transcript was missing, the Court looked to the trial court’s written orders, which:

• Summarized the State’s position that “service in this matter has not been perfected as the defendant's paperwork was sent to, and received by, the Clerk's Office in [Hillsborough-South] rather than [Hillsborough-North] where the defendant's cases are currently pending.”
• Expressly rejected that argument, finding “adequate service was made under the statute.”
• Later noted that it had considered, but rejected, the State’s contention that service was “imperfect and contrary to the statute.”

From this, the Supreme Court concluded the issue was squarely before the trial court and thus preserved, citing the principle that preservation can be established when the trial court’s analysis “demonstrate[s] that it understood and addressed” the issue. State v. Gross-Santos, 169 N.H. 593, 598 (2017).

B. Interpreting “Appropriate Court” Under RSA 606-A:2

The Court’s central task was statutory interpretation—a legal question reviewed de novo. See State v. Fortune, 177 N.H. 7, 8 (2024), 2024 N.H. 52, ¶4. It applied standard interpretive principles:

• Begin with the plain language of the statute.
• Give words their ordinary meaning.
• Give effect to every word and do not add language the legislature did not include.
• Read statutes in the context of the overall statutory scheme and the statute’s purpose.

RSA 606-A:2 provides:

The phrase “appropriate court” as used in the agreement on detainers shall, with reference to the courts of this state, mean the municipal court, the district court or the superior court.

Key points in the Court’s reasoning:

1. No textual requirement of a specific judicial district.
   The statute does not say:
   • “the superior court division where the charge is pending,” or
   • “the superior court in the judicial district where the indictment is filed.”
   It simply refers to “the superior court” within the prosecuting officer’s jurisdiction.
2. Rejection of the State’s “district-specific” reading.
   The State argued the “appropriate court” was necessarily the specific superior court division—Hillsborough-North—where the particular indictments were pending. Accepting that reading would require adding words to RSA 606-A:2 that the legislature did not enact, contrary to Fortune’s directive not to rewrite statutes under the guise of interpretation.
3. Comparison to other jurisdictions’ statutes.
   The Court invoked a comparative-interpretation canon: where other legislatures have used more specific language, but New Hampshire has not, that contrast is meaningful.
   • Federal definition: 18 U.S.C. app. 2 § 4 defines “appropriate court” as the court “in which indictments, informations, or complaints, for which disposition is sought, are pending.” (emphasis added).
   • Vermont: “the Superior Court where the Vermont charge is pending.” Vt. Stat. Ann. tit. 28, § 1531 (emphasis added).
   • Utah: “any court with criminal jurisdiction in the matter involved.” Utah Code Ann. § 77-29-6.
   These examples show other legislatures know how to restrict “appropriate court” to the specific court where the charge is pending. New Hampshire chose a broader, simpler definition; the Court concluded this choice was deliberate.
4. Legislative prerogative to amend.
   Invoking Attorney General v. Hood, 177 N.H. 176, 188 (2025), 2025 N.H. 3, ¶31, the Court noted that if the legislature disagrees with this interpretation, it may revise RSA 606-A:2; the judiciary’s role is to apply the statute as written, not to redesign it.

Accordingly, “appropriate court” for Article III(a) purposes means: any New Hampshire municipal, district, or superior court within the prosecuting officer’s jurisdiction. For a county attorney, that means any such court in that county.

C. Application to Laforest’s Case

Under RSA 7:34 and RSA 496:1, I(f), the Hillsborough County Attorney’s jurisdiction encompasses both Hillsborough-North (Manchester) and Hillsborough-South (Nashua). Thus:

• The Hillsborough County Attorney’s Office (in Nashua) was plainly the “prosecuting officer.”
• The Hillsborough County Superior Court in Nashua (Hillsborough-South) was a “superior court” within that officer’s jurisdiction.

Because Laforest’s request was delivered to:

• the Hillsborough County Attorney’s Office, and
• the Hillsborough County Superior Court at Nashua (Hillsborough-South),

the Court held that he had “caused [his request] to be delivered to the prosecuting officer and the appropriate court of the prosecuting officer’s jurisdiction,” satisfying Article III(a) and RSA 606-A:2. The 180-day clock was therefore triggered on or about December 26, 2023.

D. Article III(d): One Request, All Detainers

The Court reinforced its conclusion by invoking Article III(d). Laforest’s Form III request:

• Was directed to the Hillsborough County Attorney as the “prosecuting official.”
• Identified not only the two Hillsborough-North indictments, but also another detainer “on file” for a third charge, pending in Hillsborough-South.

Under Article III(d), a request directed to a state’s prosecuting official automatically operates as a request for final disposition of all detainers from that state. Thus, Laforest’s IAD request:

• Was valid as to the Hillsborough-South charge (which was pending in the same court that received the request), and
• Simultaneously triggered the IAD process for the two Hillsborough-North charges.

This reinforced that service on Hillsborough-South was not only textually sufficient, but practically and structurally consistent with the design of the IAD.

E. Purpose-Driven Reading: Expeditious Resolution, Not Technical Traps

The Court aligned its interpretation with the IAD’s overarching policy “to encourage the expeditious and orderly disposition of such charges and determination of the proper status of any and all detainers.” RSA 606-A:1, Art. I. It emphasized:

• The IAD is meant to protect prisoners from untried detainers that hang over them and disrupt prison programming and rehabilitation. See Bjorkman, 171 N.H. at 536.
• Delivery of the IAD request to:
  • the prosecuting officer, and
  • a superior court in the prosecutor’s county
  gave ample notice to New Hampshire that it had 180 days to resolve the pending charges, whether in North or South.
• Reading “appropriate court” narrowly, as the State urged, would turn the IAD into a technical trap where minor misdirection by out-of-state prison staff (over which the defendant has little control) could indefinitely delay a defendant’s right to a speedy disposition.

By rejecting that approach, the Court preserved the IAD’s protective function and ensured that its deadlines cannot be defeated by internal administrative misrouting.

F. Responsibility and Cooperation Under RSA 606-A:3

The Court recognized that the delay stemmed from two failures:

• The State’s five-month delay in processing paperwork and its eleventh-hour extension request.
• Hillsborough-South’s failure to docket the IAD request or to forward it to Hillsborough-North.

It cited RSA 606-A:3, which provides:

All courts, departments, agencies, officers and employees of this state . . . are hereby directed to enforce the agreement on detainers and to cooperate with one another . . . in enforcing the agreement and effectuating its purpose. (emphasis added).

Hillsborough-South’s failure to docket or forward the request contravened this statutory directive to “cooperate with one another” to effectuate the IAD’s purpose. Nevertheless, the Court made clear that:

• Such internal failures do not undo or postpone the triggering of the IAD’s 180-day clock, once valid service has occurred.
• The risk of bureaucratic inaction falls on the State and the New Hampshire courts, not on the prisoner who complied with the statutory requirements.

G. Jurisdiction vs. Service: Distinct Concepts

The State argued that Hillsborough-South lacked jurisdiction over the two Hillsborough-North indictments, because Goffstown (where the alleged offenses occurred) is in Hillsborough-North. See:

• RSA 602:1 – offenders are to be prosecuted and tried in the county or judicial district where the offense was committed.
• RSA 496:1, I(f) – classifies Goffstown as part of the northern judicial district of Hillsborough County.

The Court accepted that Laforest could not be tried in Hillsborough-South on charges arising in Goffstown. But it held this was immaterial to the IAD service question:

• The IAD’s requirement is that the prisoner serve the “appropriate court” of the “prosecuting officer’s jurisdiction.”
• It does not require service on the court that will ultimately try the case.
• Jurisdiction to try the offense is distinct from the question of which court may validly receive an IAD request and thereby trigger the speedy-trial clock.

So long as Hillsborough-South is a superior court within the Hillsborough County Attorney’s jurisdiction, service there was adequate under RSA chapter 606-A, even though the trial itself had to occur in Hillsborough-North.

H. Consequence: Mandatory Dismissal With Prejudice

Once the Court concluded that:

• Service was valid on December 26, 2023, and
• The State had not brought Laforest to trial on the Hillsborough-North indictments within 180 days and lacked good cause for an extension,

Article V(c) of the IAD mandated dismissal with prejudice. The Court recognized it had no discretion to impose a lesser sanction:

Because the defendant delivered his request for final disposition to the prosecuting officer and appropriate court of the prosecuting officer’s jurisdiction in compliance with the IAD, the trial court properly concluded that the 180-day limitation was triggered. . . . Here, the State did not bring the defendant to trial . . . within the prescribed time period. We therefore conclude that the trial court properly entered an order dismissing the two indictments with prejudice.

VII. Precedents and Authorities Cited

A. Federal IAD and Supreme Court Cases

• Fex v. Michigan, 507 U.S. 43 (1993)
  Cited for the definition of “detainer.” In Fex, the U.S. Supreme Court held that the IAD’s 180-day period begins when the prisoner’s request is delivered to the prosecuting officer and the appropriate court, not when the prisoner hands it to prison officials. Laforest is consistent with that rule: the New Hampshire Supreme Court measured the 180 days from the date of delivery to the prosecutor and court (late December 2023).
• New York v. Hill, 528 U.S. 110 (2000)
  Cited for the proposition that the IAD, as an interstate compact sanctioned by Congress, is federal law subject to federal construction. This underscores that New Hampshire must interpret its IAD provisions consistently with federal precedents, especially on structural and procedural points.

B. New Hampshire IAD and Speedy-Trial Jurisprudence

• State v. Sprague, 146 N.H. 334 (2001)
  Reaffirmed that the IAD’s purpose is to secure speedy trials for prisoners held in other jurisdictions and that the agreement is a congressionally sanctioned compact. Laforest builds on Sprague by ensuring that New Hampshire’s interpretation of “appropriate court” advances, rather than undermines, that purpose.
• State v. Bjorkman, 171 N.H. 531 (2018)
  
  • Restated that dismissal under the IAD presents a question of law reviewed de novo, while underlying factual findings are reviewed for clear error.
  • Held that the State bears the burden of proving compliance with the IAD’s time limits.
  • Emphasized that the IAD’s legislative history aims to protect prisoners from the negative consequences of outstanding detainers.
  In Laforest, the Court applied Bjorkman’s allocation of burden: the State had to show compliance or a valid basis for extension and failed to do so.
• State v. Brown, 157 N.H. 555 (2008)
  Cited for the “clearly erroneous” standard of review for factual findings. While the main issue in Laforest was legal, deference to the trial court’s fact-finding remained in place.

C. Statutory Interpretation and Appellate Procedure Cases

• State v. Fortune, 177 N.H. 7 (2024), 2024 N.H. 52
  Cited for core interpretive principles:
  • Look first to plain statutory language.
  • Give effect to each word and eschew adding words the legislature omitted.
  • Interpret statutes in harmony with the broader statutory scheme.
  Laforest is a textbook application of these principles.
• Attorney General v. Hood, 177 N.H. 176 (2025), 2025 N.H. 3
  Cited for the proposition that if the legislature disagrees with the Court’s interpretation, it may amend the statute. This underscores judicial restraint and separation of powers.
• State v. Batista-Salva, 171 N.H. 818 (2019)
  Reaffirmed the preservation requirement: issues not raised below generally cannot be raised on appeal. Applied here in evaluating whether the State’s “inappropriate court” argument was preserved.
• State v. Gross-Santos, 169 N.H. 593 (2017)
  Stands for the proposition that an issue can be deemed preserved when the trial court’s analysis demonstrates it understood and addressed it, even if briefing was not perfectly aligned. Laforest uses this rationale to find preservation despite missing transcripts.

D. Other Statutory Provisions

• RSA 606-A:1 – Enacts the IAD in New Hampshire, including Articles III and V.
• RSA 606-A:2 – Defines “appropriate court” as the municipal, district, or superior court.
• RSA 606-A:3 – Directs all New Hampshire courts, agencies, and officers to enforce and cooperate in effectuating the IAD.
• RSA 7:34 – Defines the territorial jurisdiction of county attorneys.
• RSA 496:1, I(f) – Places Goffstown in the northern judicial district of Hillsborough County, confirming Hillsborough-North as the proper trial venue for those offenses.
• RSA 602:1 – Requires offenders to be prosecuted and tried in the county or judicial district where the offense occurred.

VIII. Clarifying Key Legal Concepts

A. The IAD as an Interstate Compact and Federal Law

The IAD is not merely a state statute; it is an interstate compact—a contract between multiple states and the federal government, approved by Congress. That congressional consent elevates the compact to the status of federal law. As a result:

• State courts must interpret the IAD in a manner consistent with federal precedents (e.g., Fex, New York v. Hill).
• However, states remain free to adopt implementing provisions (like RSA 606-A:2) that clarify how federal concepts apply within their own court systems, so long as they do not conflict with the compact itself.

B. “Detainer”

A detainer is a formal notice lodged by one jurisdiction with the institution where a prisoner is confined, asking that the institution:

• Hold the prisoner for the requesting jurisdiction when his current sentence ends, or
• Notify the requesting jurisdiction before release, so it can secure the prisoner’s appearance.

Detainers can disrupt a prisoner’s rehabilitative programs, security classifications, and release planning, which is why the IAD seeks prompt resolution of charges underlying detainers.

C. “Prosecuting Officer” and “Appropriate Court”

Under the IAD:

• The “prosecuting officer” is the official responsible for prosecuting the pending charges (in New Hampshire, typically the county attorney or attorney general).
• The “appropriate court,” as defined by RSA 606-A:2, is any municipal, district, or superior court in New Hampshire within the prosecuting officer’s jurisdiction—not necessarily the specific division where the case is filed.

A prisoner triggers the 180-day clock when he causes his request to be delivered to both of these entities.

D. Dismissal “With Prejudice”

When a case is dismissed “with prejudice”:

• The prosecution is permanently terminated.
• The State cannot refile the same charges based on the same facts.

Article V(c) mandates dismissal with prejudice for IAD violations, reflecting the importance of compliance with the compact’s time limits.

E. Standards of Review: De Novo vs. Clearly Erroneous

• De novo review applies to pure questions of law, such as statutory interpretation. The appellate court gives no deference to the trial court’s legal conclusions.
• Clearly erroneous review applies to factual findings. An appellate court will not overturn such findings unless firmly convinced a mistake has been made.

In Laforest, interpretation of “appropriate court” was a question of law, reviewed de novo.

F. Preservation for Appeal

The “preservation” doctrine holds that issues must be raised at the trial level before they can be argued on appeal. This:

• Allows the trial court to correct errors in real time.
• Ensures a developed record for appellate review.

In Laforest, preservation was satisfied because the trial court’s orders explicitly recounted and rejected the State’s “inappropriate court” argument, even though no transcript was provided.

IX. Practical and Doctrinal Impact

A. Clear Rule on “Appropriate Court” in New Hampshire

State v. Laforest establishes a clear, defendant-friendly rule:

For purposes of Article III(a) of the IAD in New Hampshire, a prisoner satisfies the “appropriate court” service requirement by causing his request for final disposition to be delivered to any municipal, district, or superior court within the prosecuting officer’s jurisdiction, as defined by RSA 606-A:2, together with the prosecuting officer.

In multi-division counties like Hillsborough, this means:

• Service on either Hillsborough-North or Hillsborough-South—plus the Hillsborough County Attorney—validly triggers the 180-day clock for all Hillsborough detainers.
• The prisoner is not required to identify and serve the particular division in which each charge is physically docketed.

B. Allocation of Risk and Responsibility

The decision clarifies where the risk of administrative failure lies:

• On the State and the courts: If they receive an IAD request but do not timely process, docket, or forward it, the 180-day period still runs, and violations will result in dismissal.
• Not on the out-of-state prisoner: Once he reasonably complies with the statutory procedure (delivering the request to the prosecuting officer and a proper court within that officer’s jurisdiction), the defendant’s rights are protected; he need not police New Hampshire’s internal workflow.

This is significant because out-of-state prisoners typically have no control over:

• Which particular mailing address the sending prison chooses for a state court, or
• How New Hampshire’s various court divisions route incoming IAD paperwork.

C. Practical Guidance for Defense Counsel and Prison Officials

• Defense Counsel:
  • Should ensure that IAD requests clearly identify the relevant state, county, and charges (as Laforest’s did).
  • Can rely on Laforest to argue that service on any superior court in the relevant county is sufficient; strict district-specific targeting is not required.
  • Should monitor dates closely; 180 days from delivery to prosecutor and court is now firmly recognized as the operative period.
• Out-of-State Prison Officials:
  • Can be guided to send IAD requests to:
    • the county attorney’s office, and
    • any superior court in that county,
    confident this satisfies New Hampshire’s requirements.

D. Responsibilities for New Hampshire Courts and Prosecutors

• Courts (especially in multi-division counties):
  • Must docket IAD requests promptly.
  • Should establish internal procedures for:
    • Routing IAD requests to the correct division when charges are pending elsewhere in the county.
    • Ensuring that the prosecutor and court where the case is pending are alerted.
• Prosecutors:
  • Bear the burden of showing compliance with the IAD timelines.
  • Should not assume that any defect in intra-state routing delays the 180-day clock.
  • Must act promptly upon learning of IAD requests, including filing timely motions for continuance when necessary.

E. Potential Legislative Response

The Court expressly noted that the legislature could, if it wished, amend RSA 606-A:2 to:

• Mirror the federal definition of “appropriate court” (tying it to where the indictment is pending), or
• Adopt a Vermont-style approach that specifies the exact court where the charge is pending.

Until such an amendment occurs, Laforest is the controlling construction of “appropriate court” in New Hampshire.

F. Broader Doctrinal Significance

Doctrinally, Laforest:

• Reinforces a textualist approach to statutory interpretation, especially in the IAD context.
• Affirms that time limits in the IAD are strict and that dismissal with prejudice is a real and enforceable remedy.
• Emphasizes statutory directives of intra-state cooperation (RSA 606-A:3), highlighting that the IAD’s effectiveness depends not only on prosecutorial diligence but also on court administration.

X. Critical Evaluation

State v. Laforest is notable both for what it does and what it declines to do.

• Defendant-protective but textually grounded:
  The decision favors the defendant’s interest in a speedy trial, but it does so without judicial activism. The Court simply reads RSA 606-A:2 as written and refuses to graft in a judicial-district limitation. This is consistent with a restrained, textualist methodology.
• No “gotcha” technicalities:
  The State’s proposed reading would have subjected defendants to the risk that minor mis-addressing or misrouting by third parties would defeat their IAD rights. The Court properly declined to turn the IAD into a hyper-technical scheme where form triumphs over substance and purpose.
• Clear institutional expectations:
  By insisting that courts and prosecutors bear the consequences of inaction after valid service, Laforest should encourage:
  • Better training on IAD procedures.
  • More robust docketing and routing protocols.
  • Proactive prosecutorial case management for out-of-state defendants.
• Balanced treatment of jurisdictional concerns:
  The Court drew a careful line between:
  • Subject-matter and territorial jurisdiction to try a particular offense, and
  • Administrative sufficiency of service under the IAD.
  This avoids conflating trial-venue rules (RSA 602:1; RSA 496:1) with service requirements under RSA chapter 606-A.

One conceivable criticism is that the decision may impose substantial administrative burdens on New Hampshire courts that receive IAD paperwork for cases pending elsewhere. However, that is mitigated by:

• The explicit legislative directive in RSA 606-A:3 that all courts and agencies must cooperate to effectuate the IAD.
• The fact that interstate coordination, by its nature, requires robust internal processes; the remedy for administrative burden lies with improved systems or legislative clarification, not with narrowing defendants’ rights by judicial decision.

XI. Conclusion

State v. Laforest, 2025 N.H. 49, is now the leading New Hampshire authority on what constitutes service on the “appropriate court” under Article III(a) of the Interstate Agreement on Detainers. The Court’s core holding is that:

A prisoner satisfies the IAD’s service requirement, and triggers the 180-day speedy-trial period, by causing his request for final disposition to be delivered to the prosecuting officer and any municipal, district, or superior court within the prosecuting officer’s jurisdiction, as defined by RSA 606-A:2, regardless of the particular division where the charges are docketed.

Once valid service occurs, delays by the State or the courts—whether through neglect, failure to docket, or intra-county misrouting—do not stop the IAD clock. If the defendant is not brought to trial within 180 days, and no valid continuance, waiver, or incapacity applies, dismissal with prejudice is mandatory under Article V(c).

By affirming the dismissal of Laforest’s indictments, the New Hampshire Supreme Court underscored its commitment to the plain language and protective purposes of the IAD, clarified important procedural rules for interstate prisoners and New Hampshire officials, and signaled that compliance with statutory speedy-trial mechanisms is not optional, but a binding constraint on the State’s prosecutorial authority.

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¹ See State v. Sprague, 146 N.H. 334, 336 (2001); New York v. Hill, 528 U.S. 110, 111 (2000).