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State v. Gribble
165 N.H. 1
| N.H. | 2013
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Background

  • 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)
Read the full case

Case Details

Case Name: State v. Gribble
Court Name: Supreme Court of New Hampshire
Date Published: May 7, 2013
Citation: 165 N.H. 1
Docket Number: No. 2011-258
Court Abbreviation: N.H.