State v. Stowe, 162 N.H. 464

Defendant John Stowe was convicted of false report to law enforcement under RSA 641:4 and unsworn falsification under RSA 641:3.
The tractor at issue was allegedly stolen after John Deere could not repossess it from the defendant’s property; the defendant claimed he did not know its fate.
Police investigated after a related witness (Nixon) provided information about the tractor’s location, leading to charges against Stowe.
Stowe sought extensive cross-examination of Nixon to show bias and unreliability, and the court limited some lines of inquiry.
The State’s closing argued about Nixon’s and Stowe’s credibility, which Stowe contended mis-stated the law and shifted the burden of proof.
The trial court denied a motion to dismiss the unsworn falsification charge, but the Supreme Court reversed that conviction on statutory grounds; otherwise, the false report conviction was affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Cross-examination limitation for Nixon	Stowe claims constitutional right to robust impeachment was violated.	Limitations prevented threshold inquiry into Nixon’s bias.	Threshold inquiry allowed; no reversible error.
Curative instruction on closing argument misstatement	State misstated law; curative instruction required.	Re-instruction unnecessary; closing did not misstate law.	No error in denying re-instruction.
Dismissal of unsworn falsification charge	Form bearing notification must be lawfully authorized to prosecute.	Form authorization lacking; charge invalid.	Conviction reversed due to lack of statutory authorization.
Statutory construction of RSA 641:3,1	Notification on form is sufficient under statute.	Notification must be expressly authorized by law.	Notification must be authorized by law; form not so authorized.

State v. Brum, 155 N.H. 408 (2007) (impeachment cross-exam limits must satisfy constitutional threshold)
State v. Etienne, 146 N.H. 115 (2001) (right to confront adverse witnesses is fundamental)
State v. Miller, 155 N.H. 246 (2007) (Rule 608(b) cross-exam limits; avoid trial within a trial)
State v. DiNapoli, 149 N.H. 514 (2003) (prosecutor closing argument latitude; misstatements may trigger curative measures)
State v. Parker, 142 N.H. 319 (1997) (curative instructions when closing misstates law or procedure)
State v. Watkins, 148 N.H. 760 (2002) (curative instruction appropriate for blatant misstatement of law)
State v. Lamy, 158 N.H. 511 (2009) (statutory interpretation with plain meaning; context matters)
State v. Jennings, 159 N.H. 1 (2009) (interpret statutes with intent and overall statutory scheme)