State of New Hampshire v. William Ramsey, 166 N.H. 45

Defendant William Ramsey convicted after jury trial of second-degree assault, reckless conduct with a deadly weapon, kidnapping, and criminal threatening for violently assaulting his girlfriend in December 2010.
Victim testified Ramsey strangled and beat her with a curling iron, shoved it into her throat causing loss of consciousness and prolonged impairment of her voice; defendant sent threatening texts afterward.
Physical and medical evidence (bruises, laceration, impaired voice) and eyewitness testimony corroborated the victim’s account; defendant admitted to choking, slapping, and confronting her and to sending aggressive texts.
At trial defense sought to cross-examine the victim about an alleged false statement on her 2010 driver’s license renewal and objected to admission of testimony that Ramsey treated the victim’s dog well.
Defendant challenged imposition of consecutive sentences for second-degree assault and reckless conduct with a deadly weapon as violating the common-law merger doctrine.

Issue	State's Argument	Ramsey's Argument	Held
Whether excluding cross-examination about an alleged false driver’s-license statement violated evidentiary rules and confrontation rights	Any error was harmless given overwhelming evidence	Exclusion violated Rules 403 and 608(b) and Confrontation Clauses	Assuming error, it was harmless beyond a reasonable doubt; verdict unaffected
Admissibility of testimony that defendant treated the victim’s dog well	Evidence was admissible and not prejudicial	Testimony was irrelevant and prejudicial	Trial court did not abuse discretion; any relevance concerns did not prejudice defendant
Whether consecutive sentences for assault and reckless conduct violate merger/common-law double punishment principles	Distinct elements required different proof; consecutive sentences permissible	Sentences improperly merged under Young and common-law merger doctrine	Offenses required proof of different facts; no merger, consecutive sentences lawful
Whether Young controls merger analysis generally	Young limited to its facts; merger analyzed using double jeopardy principles	Young should prevent consecutive sentences here	Court limited Young to its facts and applied double jeopardy/merger framework, finding no merger

State v. Beede, 156 N.H. 102 (harmless-error standard and burden on State)
State v. Goodale, 144 N.H. 224 (impeachment and credibility impact)
State v. Young, 159 N.H. 332 (discussion of merger between related charges; limited to facts)
State v. McKean, 147 N.H. 198 (merger analysis where different elements require different proof)
State v. Farr, 160 N.H. 803 (lesser-included offense analysis)
Tarrant v. Ponte, 751 F.2d 459 (1st Cir. 1985) (distinguishing double-description vs. unit-of-prosecution multiple punishment cases)
Com. v. Anderson, 650 A.2d 20 (Pa. 1994) (equating merger and double jeopardy inquiry for single-act multiple punishments)