State v. Briggs

Summary

The New Hampshire Supreme Court affirmed the convictions of Daniel, Dana, and Bradley Briggs for obstructing government administration. The court held that sufficient evidence established that the defendants purposely interfered with a fish and game officer performing an official function by blocking his vehicle from leaving their property. The court rejected the defendants’ overbreadth and good-faith property-rights arguments under RSA 642:1.

Holdings

1. RSA 642:1 requires that the defendants' conscious object be to interfere with the public servant; the defendants' underlying or ultimate motive is irrelevant. The evidence was sufficient for the trial court to find that each defendant acted purposely to prevent Officer McKenzie from moving his truck.
2. The evidence was sufficient for a rational fact-finder to conclude beyond a reasonable doubt that Officer McKenzie was performing an official function while inspecting fields for deer or illegal activity and while attempting to exit the defendants' field.
3. RSA 642:1 is not unconstitutionally overbroad because the defendants had no protected freedom to interfere with an officer performing an official function.
4. RSA 642:1 does not contain a good-faith exception permitting a person to interfere with a law enforcement officer based on the person's belief that the officer has committed or is committing a crime.

Questions Presented

1. Whether the evidence was sufficient to prove that each defendant acted purposely to interfere with a public servant.
2. Whether the evidence was sufficient to prove that Officer McKenzie was performing an official function while in the defendants' field and while attempting to leave.
3. Whether RSA 642:1 is unconstitutionally overbroad because it prohibits interference with a public servant who is purporting to perform an official function.
4. Whether RSA 642:1 should contain an exception for a defendant who has a good-faith belief that the public servant has committed or is committing a crime.

Disposition

affirmed