State of New Hampshire v. Leslie M. Howe

CourtSupreme Court of New Hampshire
DecidedMay 14, 2021
Docket2020-0044
StatusUnpublished

This text of State of New Hampshire v. Leslie M. Howe (State of New Hampshire v. Leslie M. Howe) is published on Counsel Stack Legal Research, covering Supreme Court of New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of New Hampshire v. Leslie M. Howe, (N.H. 2021).

Opinion

THE STATE OF NEW HAMPSHIRE

SUPREME COURT

In Case No. 2020-0044, State of New Hampshire v. Leslie M. Howe, the court on May 14, 2021, issued the following order:

Having considered the briefs and the record submitted on appeal, we conclude that oral argument is unnecessary in this case. See Sup. Ct. R. 18(1). The defendant, Leslie M. Howe, appeals his convictions on one count of aggravated felonious sexual assault and two counts of felonious sexual assault. He argues that the Trial Court (Bornstein, J.) erred: (1) by denying defense counsel’s motion to strike a portion of the State’s closing argument; and (2) by admitting certain statements made by a police officer during the defendant’s interrogation. We affirm.

The following evidence was presented to the jury. On July 9, 2017, the defendant drove an older model sports car to a church service. The ten-year- old victim, whose home was two houses away from the church, attended the same church service alone. After the service, the victim asked the defendant whether he could look at the car. The defendant agreed and they went to the church parking lot where the victim entered the driver’s seat to examine the car. After a short time, the victim exited the car whereupon the defendant lifted him up off the ground. The defendant touched and rubbed the victim’s genitals and buttocks through his clothing before putting him back on the ground. When he returned home, the victim told his grandmother what had happened. His grandmother “struggled” with the disclosure. Two weeks later, she reported the assault to the wife of the church pastor, who then told the pastor. Following this report, the victim was interviewed by the pastor, State Police Trooper Anderson, and a forensic interviewer at the Child Advocacy Center. On each occasion, the victim described the July 9, 2017 assault.

In September 2017, the defendant voluntarily met with Trooper Anderson and Detective Stephens for an interview. He initially claimed that the victim had become panicked while sitting in the sports car and that when he reached into the car to lift him out, the defendant might have inadvertently touched the victim’s buttocks and genitals. As the interview continued, the defendant conceded: “I touched him inappropriately.”

Based on its investigation, the State charged the defendant with one count of aggravated felonious sexual assault and two counts of felonious sexual assault. The State’s witnesses at trial included the victim, his pastor, his grandmother, Trooper Anderson, and Detective Stephens. When the State sought to introduce excerpts from the defendant’s September interview with the State Police, defense counsel moved to strike several portions. The trial court reviewed with counsel the challenged portions of the interview and ruled on approximately 25 excerpts, granting approximately half of the defendant’s requests.

Following a jury trial, the defendant was convicted on all three charges. This appeal followed.

The defendant first argues that the trial court erred in denying his motion to strike a portion of the State’s closing argument.1 He specifically cites the following excerpt:

. . . he’s told a number of different people about this embarrassing situation, even though there’s no corroboration that’s necessary under the law. . . . And you’ve heard [the victim]’s testimony and the testimony is important. And he’s been consistent. Otherwise, you would have heard testimony — you would have heard the Defense counsel attacking his credibility. You would have heard that he’s made 50 statements. You didn’t hear any of that because he’s been absolutely consistent that he was outside of the car, getting out.

The defendant argues that, although the jury heard testimony that the victim “spoke to several people about his allegation against [the defendant], that testimony was not admitted for substantive or credibility-rehabilitation purposes.” Therefore, he concludes, “when the prosecutor in closing urged the jury to use those statements for a credibility-enhancing purpose, the prosecutor argued facts for a purpose for which they were not in evidence. In that sense, the prosecutor argued facts not in evidence.” The defendant also contends that the State’s observation about defense counsel’s “failure to impeach [the victim] with prior inconsistent statements” “improperly shifted the burden of proof onto the defendant.”

To determine whether the trial court erred in denying the defendant’s motion to strike, we consider whether the prosecutor’s statements were impermissible comments and, if so, whether the error requires reversal of the verdict. See State v. Hearns, 151 N.H. 226, 232-33 (2004). In making this determination, we balance a prosecutor’s broad license to fashion argument with the need to ensure that a defendant’s rights are not compromised. Id. at 233.

If we conclude that the prosecutor’s statements were improper, the defendant asks us to apply the following three factors to determine whether the improper statement requires reversal: (1) whether the misconduct was isolated and/or deliberate; (2) whether the trial court gave a strong and explicit

1 We note that, although defense counsel moved to strike a portion of the State’s argument

after the State completed its closing, he did not request a mistrial.

2 cautionary instruction; and (3) whether any prejudice surviving the court’s instruction likely could have affected the outcome of the case. See State v. Ellsworth, 151 N.H. 152, 155 (2004). We will assume without deciding that the test that we apply when determining whether prejudicial comments by a prosecutor require that the trial court grant a requested mistrial also applies in the absence of such a request.

We turn first to the question of whether the prosecutor argued facts not in evidence. As the trial court observed, the jury heard evidence from several witnesses that the victim reported that he had been inappropriately touched by the defendant. That the victim made the disclosures was not disputed; rather, a major factual dispute was whether the victim was inside or outside of the car when the defendant lifted him up. Even if we assume without deciding that the prosecutor’s limited statement about the consistency of the victim’s statements was improper, the misstatement was cured by the trial court’s instruction to the jury.

Prior to closing arguments, the trial court instructed the jury:

A person accused of a crime has an absolute right not to take the witness stand to testify. The fact that the Defendant did not testify must not be considered by you in any way in deciding this case. The burden is on the State to prove the Defendant guilty beyond a reasonable doubt. The Defendant has no obligation to present any evidence or to prove his innocence.

You will hear the lawyers discuss the facts and the law in their arguments to you. These arguments are not evidence. Their purpose is to help you understand the evidence and the law. If the lawyers state the law differently from the law as I explained it to you, then you must follow my instructions and ignore the statements of the lawyers. If the lawyers state the evidence differently from the way in which you recall it, then you should follow your own memory of what the evidence was.

(Emphasis added.)

We next consider whether the prosecutor shifted the burden of proof to the defendant when he cited defense counsel’s failure to impeach the victim’s testimony. The defendant specifically cites the prosecutor’s argument that the jury would have heard defense counsel attacking the victim’s credibility if the victim had fabricated the assault; he contends that this argument is “materially indistinguishable” from the argument that we found improper in Hearns.

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Related

State v. Fowler
567 A.2d 557 (Supreme Court of New Hampshire, 1989)
State v. Ellsworth
855 A.2d 474 (Supreme Court of New Hampshire, 2004)
State v. Hearns
855 A.2d 549 (Supreme Court of New Hampshire, 2004)
State v. Willis
75 A.3d 1068 (Supreme Court of New Hampshire, 2013)

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Bluebook (online)
State of New Hampshire v. Leslie M. Howe, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-new-hampshire-v-leslie-m-howe-nh-2021.