Summary
The New Hampshire Supreme Court reversed Jack Haycock’s conviction for second degree assault. The court held that the circumstantial evidence did not exclude the reasonable possibility that Haycock’s father, rather than Haycock, caused the victim’s broken nose, and therefore was insufficient to sustain the conviction.
Topics
Practice areas
Questions Presented
- Whether the evidence was sufficient to sustain Haycock's conviction for second degree assault when the State could not exclude the rational inference that his father caused the victim's broken nose.
- Whether the indictment was impermissibly amended by instructing the jury on principal liability when the indictment charged accomplice liability.
- Whether the prosecutor misstated the evidence and argued facts not in evidence during closing argument.
Holdings
- The evidence was insufficient to prove beyond a reasonable doubt that Haycock knowingly or recklessly caused the victim's serious bodily injury because it did not exclude the rational inference that Haycock's father caused the broken nose.
Key quotations
“When the evidence presented is circumstantial, it must exclude all rational conclusions except guilt in order to be sufficient to convict.” (146 N.H. at 303)
“Taking all the evidence in the light most favorable to the State, it cannot be said beyond a reasonable doubt that the circumstantial evidence necessarily excluded the rational inference that someone other than the defendant, namely, his father, caused the victim’s broken nose.” (146 N.H. at 304)
Factual background
Haycock and his father encountered the victim and the victim's friends at a bar, and an altercation followed. The victim testified that Haycock smacked him in the face and that Haycock's father struck him shortly afterward, but the victim could not identify which blow broke his nose. The medical evidence established blunt trauma and was consistent with a left-handed punch, while Haycock was right-handed; the record therefore left open the rational possibility that his father caused the injury.
Procedural history
Haycock was charged with accomplice liability for second degree assault. Over his objection, the superior court also instructed the jury that it could convict him of principal second degree assault. The jury acquitted him of accomplice liability but convicted him of second degree assault; the Supreme Court of New Hampshire reversed because the evidence was insufficient to establish beyond a reasonable doubt that Haycock caused the victim's serious bodily injury.