State v. Jonathan Folds

Summary

The Supreme Court of New Hampshire held that the firearm seized during a lawful drug search was justified under the plain view exception, and that RSA 159:3-a applies only when a defendant’s qualifying convictions arise from three or more separate criminal episodes. Accordingly, the court reversed the trial court’s suppression ruling, affirmed the dismissal of the armed‑career‑criminal indictments, and remanded for further proceedings.