State v. Gribble
165 N.H. 1
| N.H. | 2013Background
- Gribble was convicted by jury of first‑degree murder, attempted murder, conspiracy to commit first‑degree murder, witness tampering, and conspiracy to commit burglary for a Mont Vernon home invasion that killed Kimberly Cates.
- He pleaded not guilty by reason of insanity; the jury found him sane and guilty on all charges.
- Pretrial, Gribble moved to suppress statements to state police arguing violation of right to remain silent; the court denied suppression.
- Pretrial, he moved for a venue change due to extensive pretrial publicity and Spader’s earlier trial; the court denied the change.
- The trial court later instructed the jury on insanity using the 2005 Model Jury Instructions with specified factors; Gribble objected.
- On appeal, the New Hampshire Supreme Court affirmed all convictions and rejected each challenge.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Miranda suppression of statements | State contends no interrogation after invocation; statements were voluntary and initiated by Gribble. | Gribble argues the officer’s responses after invocation constituted the functional equivalent of interrogation. | No improper interrogation; suppression denial affirmed. |
| Venue change due to pretrial publicity | State argues publicity did not create presumptive prejudice; voir dire ensured impartial jurors. | Gribble asserts pervasive publicity deprived him of fair trial in Hillsborough County. | No manifest error; no change of venue required. |
| Jury instruction on insanity | State contends instructions properly set forth factors jurors may consider without implying defect in the State’s theory. | Gribble claims the factors emphasized by the court favored the State’s theory of insanity. | Instructions, viewed as a whole, did not improperly privilege the State’s theory; no error. |
Key Cases Cited
- State v. Ball, 124 N.H. 226 (N.H. 1983) (Miranda-related constitutional analyses)
- State v. Jeleniewski, 147 N.H. 462 (N.H. 2002) (Miranda rights; admissibility standard)
- In re Rhode Island v. Innis, 446 U.S. 291 (U.S. 1980) (functional equivalent of interrogation)
- State v. Plch, 149 N.H. 608 (N.H. 2003) (reinitiation of questioning after invocation; waiver standard)
- State v. Gravel, 135 N.H. 172 (N.H. 1991) (perceptions focus in interrogation analyses)
