Jonathan Wolfgram v. New Hampshire Department of Safety, 140 A.3d 517

Between 2002–2007 Wolfgram accumulated multiple motor-vehicle convictions; DOS certified him a habitual offender and revoked his license for four years.
Wolfgram was later decertified (2011) and placed on probationary status; he then obtained ~17 annulments (2012–2013) for various motor-vehicle convictions, including those underlying the habitual-offender certification.
DOS removed the annulled convictions from his motor-vehicle record but retained notations reflecting his prior habitual-offender certification and decertification.
Wolfgram asked DOS to remove all habitual-offender notations from his official motor-vehicle record, arguing retention undermined RSA 651:5 annulment protections; DOS denied relief and he appealed to superior court.
The superior court upheld DOS; the Supreme Court reviewed statutory interpretation de novo and reversed, holding that while DOS must keep an internal record of certification, notations revealing annulled convictions cannot remain on the publicly accessible motor-vehicle record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether DOS may keep habitual-offender notations on the public motor-vehicle record after underlying convictions were annulled	Wolfgram: retaining notations defeats annulment statute’s purpose; public record must not reveal annulled convictions	DOS: habitual-offender designation is a civil action not subject to annulment; RSA 651:5 X(a) allows annulled convictions to be counted toward habitual-offender status and statutes require DOS to keep the certification on its record	Held: DOS may keep an internal record of certification, but must remove or segregate habitual-offender notations from the publicly accessible motor-vehicle record when underlying convictions are annulled to preserve annulment protections

JMJ Properties, LLC v. Town of Auburn, 168 N.H. 127 (statutory interpretation reviewed de novo)
Choquette v. Roy, 167 N.H. 507 (statutory construction principles)
Appeal of Wilson, 161 N.H. 659 (avoiding interpretations that render statutes nullities)
State v. Bulcroft, 166 N.H. 612 (construe statutes to avoid absurd or unjust results)
Brown v. Brown, 133 N.H. 442 ("in all respects" in annulment statute interpreted broadly)
State v. Roe, 118 N.H. 690 (purpose of annulment statute: reduce collateral consequences)
Panas v. Harakis & K-Mart Corp., 129 N.H. 591 (annulment necessarily discloses fact of conviction)
Lovejoy v. Linehan, 161 N.H. 483 (acknowledging limited circumstances where annulled convictions remain relevant)
Duchesne v. Hillsborough County Attorney, 167 N.H. 774 (procedures for separating confidential from public records)
State v. Fitzgerald, 137 N.H. 23 (habitual-offender certification is a civil designation)