The State of New Hampshire v. Shawn R. Cunningham

Summary

The court affirmed the defendant’s convictions for two counts of simple assault, holding that the evidence was sufficient for a rational juror to find that both uses of force were unprivileged and unjustified. The defendant’s belief that force was necessary either to detain the victim or to defend against imminent non-deadly force was subject to an objective reasonableness standard, and the evidence supported a finding that his belief was unreasonable. The court also held that, because the defendant presented evidence after moving to dismiss, the appeal was reviewed under the sufficiency-of-the-evidence standard based on the entire trial record.