The State of New Hampshire v. John Sullivan (New Hampshire 1988)

Summary

The court affirmed Sullivan’s convictions for second-degree murder and first-degree murder. It held that the State properly introduced evidence concerning Sullivan’s violence when intoxicated and his attitudes toward women to rebut his testimony, impeach related expert testimony, and prove intent; that the evidence supported premeditation and deliberation in Pike’s killing; and that New Hampshire’s insanity rule satisfies due process.

Holding

Admission of character evidence and denial of mistrial. The trial court properly denied the motion for a mistrial because the challenged evidence was admissible to rebut impressions created by Sullivan’s testimony, impeach his credibility and the related expert testimony, and prove intent rather than to show that he acted in conformity with a bad character. Any possible prejudice was also cured by limiting instructions.

Sufficiency of evidence of premeditation and deliberation. The evidence was sufficient for a rational juror to find premeditation and deliberation in Pike’s murder, so the trial court properly denied the motion to dismiss the first-degree murder charge.

Due-process challenge to New Hampshire’s insanity rule. New Hampshire’s insanity rule satisfies due process despite placing the insanity determination with the jury and not providing the specific standard or appellate-review framework urged by Sullivan.

Summary

Holding

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