State v. BELONGA, 163 N.H. 343

Defendant Nicole Belonga was convicted of manslaughter for the death of her infant daughter Rylea.
Rylea collapsed while in the care of a babysitter; injuries were determined non-accidental after hospital/medical review.
Police interviewed Belonga at the Nashua Police Station; initial interview was not videotaped, later portion was videotaped after Miranda warnings.
Defendant moved to suppress the statements as involuntary; the trial court denied suppression and admitted the statements.
Two evidentiary issues followed: (1) admission of Belonga’s 2005 statement striking Rylea, and (2) admission of evidence of anger management problems; the court found errors and the State conceded but upheld the conviction as harmless.
The Supreme Court of New Hampshire affirmed, holding the statements were voluntary beyond a reasonable doubt and that the other-acts evidence was admissible only for proper purposes, yet ultimately harmless error justified affirmance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Voluntariness of statements under NH and US Constitution	Belonga argues statements were involuntary due to police tactics.	Belonga contends coercive tactics and misleading statements overbore her will.	Statements voluntary beyond reasonable doubt.
Admission of prior act—2005 striking incident under Rule 404(b)	Statement should be admissible as party admission and not unduly prejudicial.	Prior act evidence was unfairly prejudicial and improper under Rule 404(b).	Statement improperly admitted under Rule 404(b); sister’s testimony also improper.
Admission of anger-management evidence	Evidence relevant to state of mind/motive.	Evidence is improper character evidence not tied to charged crime.	Error in admitting anger-management evidence deemed harmless beyond a reasonable doubt.
Harmless-error assessment	Admission errors could have affected the verdict.	Errors potentially prejudicial but not outcome-determinative.	Conviction affirmed as harmless error; overwhelming non-constitutional evidence of guilt.

State v. Aubuchont, 147 N.H. 142 (2001) (voluntariness standard under NH Constitution)
State v. Ball, 124 N.H. 226 (1983) (NH adopts beyond a reasonable doubt standard for voluntariness under state constitution)
State v. Hammond, 144 N.H. 401 (1999) (totality of the circumstances in voluntariness analysis)
State v. Parker, 160 N.H. 203 (2010) (factors in determining freely chosen statements)
State v. Hernandez, 162 N.H. 698 (2011) (misleading statements not per se involuntary; voluntariness depends on totality)
State v. Bilodeau, 159 N.H. 759 (2010) (Miranda compliance as one factor in voluntariness; videotaped portion significant)
State v. Addison, 160 N.H. 493 (2010) ( Rule 404(b) prong analysis for prior acts)
State v. Nightingale, 160 N.H. 569 (2010) (balance probative value vs. unfair prejudice in 404(b))
State v. Drew, 137 N.H. 644 (1993) (prejudice concerns in prior-acts evidence)