State v. Botelho, 83 A.3d 814

On July 13, 2010 Jessica Botelho left her two young sons (ages ~1 and 2) alone in a bathtub with ~2–3 inches of water, went to a porch and used her laptop; one child later suffered fatal near-drowning injuries.
Forensic analysis showed nearly continuous activity on Botelho’s computer at myfreeimplants.com from 4:20–5:02 p.m.; Botelho admitted she "posted a blog" on that site during the relevant period.
The State introduced the website name and descriptive references at trial; the court redacted explicitly sexual or salacious content and questioned jurors about potential bias regarding breast augmentation.
Botelho was convicted by a jury of manslaughter, negligent homicide (alternative), and reckless conduct; she appealed, challenging (1) admission of the website-identifying evidence and (2) exclusion of two portions of her recorded police interview under the completeness doctrine.
The trial court excluded two contested portions of the videotaped police interview; Botelho argued exclusion violated the doctrine of completeness (N.H. R. Ev. 106) and that website references were irrelevant and unfairly prejudicial (N.H. R. Ev. 401, 403).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of website-identifying information (relevance/Rule 403)	State: website name/addresses showed the length and interactive nature of computer use during critical period and explained gaps in activity	Botelho: name/content irrelevant; only duration mattered; name risked unfair moral prejudice and invited juror bias	Even if admission erred, error was harmless beyond a reasonable doubt given overwhelming alternative evidence of extended computer use, bathtub evidence, and causation — affirm conviction
Exclusion of two portions of recorded police interview (Rule 106/completeness)	State: redacted interview was offered as party-opponent admission; excluded sections not necessary for fairness	Botelho: excluded passages (emotional statements, insistence she "didn’t do this," concern for surviving child) were needed to prevent misleading, out-of-context presentation	Trial court did not abuse discretion; excluded portions did not "shed light" on the admitted parts and were cumulative of emotional expressions already before jury — no prejudicial error

State v. Jenot, 158 A.3d 181 (N.H. 2008) (relevance and Rule 403 unfair prejudice standard)
State v. Enderson, 148 A.2d 252 (N.H. 2002) (harmless error standard for evidentiary rulings)
State v. Pelletier, 149 A.2d 243 (N.H. 2003) (prosecution’s burden to prove harmless error beyond a reasonable doubt)
State v. Belonga, 163 A.3d 343 (N.H. 2012) (definition and proof of recklessness under RSA 626:2)
State v. Keith, 136 A.2d 572 (N.H. 1992) (Rule 106 discretion to admit additional parts to avoid misleading impression)
State v. Warren, 143 A.2d 633 (N.H. 1999) (doctrine of completeness and appellate review for abuse of discretion)
Beech Aircraft Corp. v. Rainey, 488 U.S. 153 (1988) (federal Rule 106 partially codifies doctrine of completeness)