State of New Hampshire v. Jeffrey Maxfield
167 N.H. 677
| N.H. | 2015Background
- On Dec. 14, 2011 defendant Jeffrey Maxfield allegedly committed criminal mischief (misdemeanor).
- Police prepared a complaint on Dec. 21, 2011 and a justice of the peace issued an arrest warrant that day.
- Defendant was not arrested until Aug. 6, 2013; the State filed the complaint in court Aug. 9, 2013.
- Defendant moved to dismiss asserting the one-year statute of limitations had expired; trial court granted dismissal, citing an 18‑month delay between issuance and execution of the warrant.
- State appealed; the Supreme Court of New Hampshire reviewed statutory interpretation of RSA 625:8 (limitations, commencement, tolling).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether issuance of an arrest warrant within the limitations period tolls the statute regardless of how long it takes to execute the warrant | State: RSA 625:8(V) is plain — a prosecution "commenced" when a warrant is issued, so tolling occurs on that issuance date without any reasonableness inquiry | Maxfield: Statute should be construed to require that a warrant relied on to toll limitations be executed within a reasonable time after the limitations period would have expired; otherwise statute's notice and anti‑staleness functions are defeated | Court held for the State: literal reading controls — issuance of a warrant commences prosecution and tolls the limitations period; no reasonableness requirement is implied; reversed trial court dismissal |
Key Cases Cited
- Appeal of Local Gov’t Ctr., 165 N.H. 790 (N.H. 2014) (principles of statutory interpretation; plain meaning controls)
- State v. Brooks, 162 N.H. 570 (N.H. 2011) (discussing when speedy trial protections commence)
- State v. Breest, 167 N.H. 210 (N.H. 2014) (look beyond statute only if plain reading produces absurd result)
- State v. Varagianis, 128 N.H. 226 (N.H. 1986) (due process may bar prosecutions after arbitrary delays)
- State v. Knickerbocker, 152 N.H. 467 (N.H. 2005) (statutes of limitation reflect legislative balance between state and defendant)
- United States v. Marion, 404 U.S. 307 (U.S. 1971) (purposes of statutes of limitation include avoiding stale prosecutions)
- State v. Philibotte, 123 N.H. 240 (N.H. 1983) (statutes of limitation as primary safeguard against stale criminal charges)
- Morey v. State, 103 N.H. 529 (N.H. 1961) (statutes of limitation construed liberally in favor of the accused)