State v. Hodges

2024 N.H. 44, 324 A.3d 961
CourtSupreme Court of New Hampshire
DecidedAugust 27, 2024
Docket2023-0121
StatusPublished
Cited by3 cases

This text of 2024 N.H. 44 (State v. Hodges) 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 v. Hodges, 2024 N.H. 44, 324 A.3d 961 (N.H. 2024).

Opinion

NOTICE: This opinion is subject to motions for rehearing under Rule 22 as well as formal revision before publication in the New Hampshire Reports. Readers are requested to notify the Reporter, Supreme Court of New Hampshire, One Charles Doe Drive, Concord, New Hampshire 03301, of any editorial errors in order that corrections may be made before the opinion goes to press. Errors may be reported by email at the following address: reporter@courts.state.nh.us. Opinions are available on the Internet by 9:00 a.m. on the morning of their release. The direct address of the court’s home page is: https://www.courts.nh.gov/our-courts/supreme-court

THE SUPREME COURT OF NEW HAMPSHIRE

___________________________

Belknap Case No. 2023-0121 Citation: State v. Hodges, 2024 N.H. 44

THE STATE OF NEW HAMPSHIRE

v.

JERAMY HODGES

Argued: April 23, 2024 Opinion Issued: August 27, 2024

John M. Formella, attorney general, and Anthony J. Galdieri, solicitor general (Audriana Mekula, assistant attorney general, on the brief and orally), for the State.

Jason M. Novak, public defender, of Orford, on the brief and orally, for the defendant.

MACDONALD, C.J.

[¶1] The defendant, Jeramy Hodges, appeals his convictions, following a jury trial in the Superior Court (Leonard, J.), on five counts of aggravated felonious sexual assault (AFSA), including: two counts alleging cunnilingus; two counts alleging vaginal intercourse; and one count alleging a pattern of sexual assaults that subjected the victim to sexual contact, causing her to suffer a “serious personal injury” of “severe mental anguish or trauma.” See RSA 632-A:2, I(j) (2016 & Supp. 2023); RSA 632-A:2, III (2016); RSA 632-A:3, I (2016); RSA 632-A:1, I-c (2016). On appeal, the defendant argues that the trial court: (1) erred in failing to dismiss the pattern sexual assault indictment for insufficient evidence; and (2) may have erred in failing to disclose New Hampshire Division for Children, Youth and Families (DCYF) records and the victim’s counseling records reviewed in camera. We affirm.

I. Background

[¶2] The jury could have found, or the record otherwise supports, the following facts. When the victim was in middle school, she primarily lived with her mother, the defendant, and her younger siblings.

[¶3] Between December 2017 and December 2020, the defendant subjected the victim to sexual contact multiple times. The victim testified that when her mother was working nights, the defendant would come into her room when her siblings were sleeping and would touch her vagina under her clothes. She further testified that “[t]here was a time or two he had me touch his penis” under his clothes. Between September 1, 2019 and December 1, 2019, the defendant, on two occasions, committed vaginal intercourse and cunnilingus on the victim. She disclosed the assaults in April 2021.

[¶4] Prior to trial, the defendant filed an assented-to motion for in camera review of “any and all DCYF records regarding” the victim, based on the significant role her credibility would play at trial. The trial court granted the defendant’s motion. After reviewing the DCYF records in camera, the trial court issued an order disclosing some of the records, finding that “the enclosed records are discoverable under the applicable standards.”

[¶5] On or before the day the trial was scheduled to begin in November 2022, the parties learned that the victim had attended counseling following her disclosure of the assaults in April 2021. The court ordered that her counseling records be produced for in camera review. After reviewing the counseling records in camera, the court issued an order finding that “none of the records are discoverable under the applicable standards.” At a hearing the next day, the court denied defense counsel’s request to reconsider its decision.

[¶6] The trial court conducted a two-day trial in November 2022. After the State rested, defense counsel moved to dismiss all the indictments, arguing that the State had not met its burden of proof. Regarding the pattern AFSA charge, defense counsel did not present an argument about the “extreme mental anguish or trauma” element of the offense. RSA 632-A:1, III; see RSA 632-A:2, I(j); RSA 632-A:3, I. The court denied the motion. The defendant then

2 presented evidence. The jury found the defendant guilty on all counts. This appeal followed.

II. Analysis

A. Sufficiency of the evidence

[¶7] We first address the defendant’s argument that “[t]he State failed to present sufficient evidence that [he] inflicted serious personal injury on [the victim] because the State was required to prove that the alleged pattern assault caused [her] to suffer extreme mental anguish or trauma.” The defendant asserts that “[n]o rational trier of fact could find, based on what [the victim] said at trial, that she suffered extreme mental anguish or trauma because [she] only testified to ordinary thoughts and feelings without any evidence about their degree, severity, or frequency.” To the extent this argument is not preserved, the defendant invokes our plain error rule. See Sup. Ct. R. 16-A.

[¶8] The State contends that the defendant has not preserved this argument for appellate review because he did not raise it before the trial court. We agree with the State and therefore analyze the defendant’s unpreserved sufficiency argument for plain error. See Sup. Ct. R. 16-A; State v. Morrill, 169 N.H. 709, 720 (2017) (reviewing an unpreserved sufficiency of the evidence challenge under plain error); State v. Houghton, 168 N.H. 269, 272 (2015) (reviewing an unpreserved sufficiency of the evidence challenge under plain error); State v. Guay, 162 N.H. 375, 380 (2011) (reviewing an unpreserved sufficiency of the evidence challenge to an AFSA conviction under plain error); State v. Lopez, 162 N.H. 153, 159 (2011) (reviewing an unpreserved sufficiency of the evidence challenge under plain error).

[¶9] Under the plain error rule, we may consider errors not raised before the trial court. Guay, 162 N.H. at 380; see Sup. Ct. R. 16-A. However, the rule should be used sparingly, its use limited to those circumstances in which a miscarriage of justice would otherwise result. Guay, 162 N.H. at 380. To find plain error: (1) there must be an error; (2) the error must be plain; (3) the error must affect substantial rights; and (4) the error must seriously affect the fairness, integrity or public reputation of judicial proceedings. Id.

[¶10] When considering a challenge to the sufficiency of the evidence, we objectively review the record to determine whether any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt, considering all the evidence and all reasonable inferences therefrom in the light most favorable to the State. State v. Pierce, 176 N.H. ___, ___ (2024), 2024 N.H. 12, ¶18. The trier of fact may draw reasonable inferences from facts proved as well as from facts found as the result of other inferences, provided they can be reasonably drawn therefrom. Id. We examine each evidentiary item in the context of all of the evidence, and not in isolation. Id. Because a

3 challenge to the sufficiency of the evidence raises a claim of legal error, our standard of review is de novo. Id. The defendant has the burden of demonstrating that the evidence was insufficient to prove guilt. Id. at ___, 2024 N.H. 12, ¶19. Because, here, the defendant chose to present a case, we review the entire trial record to determine the sufficiency of the evidence. State v. Saintil-Brown, 172 N.H. 110, 117 (2019).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Reed
2025 N.H. 34 (Supreme Court of New Hampshire, 2025)
State of New Hampshire v. Kierran Pierce
Supreme Court of New Hampshire, 2025
State v. Warren
2025 N.H. 5 (Supreme Court of New Hampshire, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2024 N.H. 44, 324 A.3d 961, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-hodges-nh-2024.