New Hampshire v. Maxfield
Annotate this CaseIn 2011, Lincoln police charged defendant Jeffrey Maxfield with criminal mischief, a class A misdemeanor offense. The complaint alleged that defendant had recklessly damaged another’s property at a motel in Lincoln. A justice of the peace issued an arrest warrant one week later, but defendant was not arrested until 2013. The State filed the complaint in court three days after the defendant’s arrest. Defendant moved to dismiss the charge, arguing that the delay between the issuance of the arrest warrant and his arrest violated his rights to a speedy trial, due process, and fundamental fairness under both the New Hampshire and United States Constitutions. The trial court denied this motion. Defendant then filed a motion to reconsider, which the court also denied. Defendant filed a second motion to dismiss, arguing that the charge was barred by the one-year statute of limitations applicable to misdemeanor level offenses. The trial court granted this second motion to dismiss. In denying the State’s motion to reconsider, the trial court stated that it “was unreasonable for there to be a delay of eighteen months between the commencement of prosecution and the commencement of the adversarial proceeding.” This appeal followed. The Supreme Court found in its review of the State's arguments on appeal that under the plain language of the statute, the one-year limitations period for the defendant’s criminal mischief charge began to run on December 15, 2011, the day after all the elements of the alleged offense had occurred. Because the language of RSA 625:8 was plain and unambiguous, and because the Court refused to "add language to a statute that the legislature did not see fit to include," the trial court erred by reading a reasonableness standard into the statute. The Court found that the statute of limitations was not violated in this case, and that the trial court erred in dismissing the State's complaint.
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