State v. Labranche, 156 N.H. 740

Summary

The Supreme Court of New Hampshire affirmed Michael J. Labranche's first-degree murder conviction. The court held that the trial court properly admitted a psychiatrist's expert testimony that Labranche's conduct was not the product of mental illness under New Hampshire's insanity defense. The court also declined to address the defendant's due process argument because it was inadequately developed.

Holdings

1. Expert psychiatric testimony that the defendant's conduct was the product, or was not the product, of mental illness may be admissible under New Hampshire Rule of Evidence 702 when the psychiatrist's specialized knowledge may assist the jury in understanding the complexities of mental illness and determining that factual issue.
2. The court declined to address the defendant's due process argument because he offered only a passing reference to due process without a developed constitutional argument.

Questions Presented

1. Whether the trial court abused its discretion under New Hampshire Rule of Evidence 702 by admitting psychiatric expert testimony that the defendant's conduct was not the product of mental illness.
2. Whether admission of the testimony rendered the trial fundamentally unfair and violated the defendant's due process rights under the New Hampshire Constitution.

Disposition

affirmed