Supreme Court of New Hampshire

State of New Hampshire v. Bryan Weston Luikart

May 4, 2021

Summary

The Supreme Court of New Hampshire reversed the Circuit Court’s order imposing a portion of Bryan Weston Luikart’s suspended sentence, holding that the State failed to prove by a preponderance that Luikart committed witness tampering and thus violated the good‑behavior condition. The Court clarified that the mens‑rea element of RSA 641:5, I requires a belief that an official proceeding is probable, not merely possible, and that the State must prove the essential elements of the alleged criminal conduct even absent a conviction.