United States v. Ryan Howe, 167 N.H. 143

The First Circuit certified a question to New Hampshire Supreme Court about juror eligibility where a felon’s conviction is eligible for annulment but not yet annulled.
Howe was federally charged with possession of a firearm by a felon based on a prior state felony conviction.
Section 921(a)(20) excludes expunged, set aside, or rights-restored convictions; the government concedes voting and public-office rights were restored before the offense.
RSA 500-A:7-a, V disqualifies a juror who has a felony not annulled or not eligible for annulment; the district court adopted the defendant’s view that eligibility alone matters.
RSA 651:5 governs annulments; paragraphs V and VI bar annulment for violent crimes, certain offenses, or multiple offenses; temporal eligibility interacts with these bars.
Legislative history shows a shift from requiring actual annulment to also considering eligibility for annulment to widen the jury pool.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a felon eligible for annulment but not yet annulled can serve as a juror	Howe (United States) argues disqualification persists.	Howe contends eligibility for annulment suffices to avoid disqualification.	Yes; eligible-for-annulment felons may serve as jurors despite no actual annulment.

United States v. Estrella, 104 F.3d 3 (1st Cir. 1997) (restoration of voting, public-office, and jury rights for § 921(a)(20) exception)
Town of Newbury v. N.H. Fish & Game Dep’t, 165 N.H. 142 (2013) (plain-meaning interpretation and statutory context in NH law)
Bradley v. City of Manchester, 141 N.H. 329 (1996) (interpretation of statutes in light of legislative intent and related schemes)
Appeal of Naswa Motor Inn, 144 N.H. 89 (1999) (method for resolving statutory ambiguity via legislative history)
Strike Four v. Nissan N. Am., 164 N.H. 729 (2013) (textual analysis and interpretation principles in NH cases)