New Hampshire v. BelongaAnnotate this Case
The main issue on appeal was whether Defendant's statements to police during an interview were voluntary. A portion of the interview was videotaped. Paramedics were called to the home of Defendant Nicole Belonga when Defendant's twenty-one-month-old child was sick. The child was left in the care of Defendant's boyfriend David Kaley who was living with Defendant at the time. The child suffered a seizure and was admitted to the hospital. She was discovered to have serious brain injuries and later transported to a hospital in Boston with a pediatric intensive care unit. Nashua Police arrived at the hospital and requested Defendant give a statement to them at the station. At first she did not agree to go so that she might be with her daughter in Boston, but Defendant later acquiesced. Detectives made clear that Defendant was at the police station voluntarily, but in her pre-trial motion, Defendant argued that her statements to the detectives were involuntary and the admission of those statements at trial would violate her constitutional rights. After a hearing, the court denied her motion. Her statements were admitted at trial through the videotape and the testimony of the detectives. Upon review, the Supreme Court affirmed the trial court's denial of Defendant's pre-trial motion: "the jury had before it overwhelming evidence of the defendant’s guilt. The defendant’s description of the incidents in which she used physical force against her daughter closely correspond with the doctors' testimony. The defendant's testimony, together with the doctors' testimony, strongly supports the conclusion that the defendant was caring for her daughter when [the] injuries occurred. The defendant made several statements suggesting she had had used too much physical force against her daughter and that she did something wrong. Also, the defendant's general description of the events paints a picture of a person using unwarranted and dangerous physical force against a very young child. Accordingly, [the Court] concluded that the evidentiary errors at trial were harmless beyond a reasonable doubt."