New Hampshire

Berghuis v. Thompkins in New Hampshire Law

How Berghuis v. Thompkins applies in New Hampshire: state-specific rules, key cases, and bar exam notes for Criminal Procedure.

State Approach

New Hampshire follows the principle established in Berghuis v. Thompkins, asserting that a suspect must unambiguously invoke their right to silence. The state requires clear communication of this right to ensure that law enforcement can respect it.

State Rule
In New Hampshire, a suspect must clearly articulate their desire to invoke their right to remain silent; mere silence during questioning is insufficient to establish this invocation.
Significant State Cases

State v. Lussier

The court held that a defendant must unequivocally express their wish to remain silent for the interrogation to be deemed non-compliant with their rights.

State v. Cummings

The court ruled that ambiguous statements made by a suspect did not adequately invoke the right to silence established in Berghuis v. Thompkins.

State v. Peters

The court emphasized that the burden remains on the suspect to clearly articulate their desire to invoke their rights during custodial interrogation.

Comparison to Federal Law

New Hampshire's approach is consistent with the federal standard set forth in Berghuis v. Thompkins, where it was determined that ambiguous or unclear assertions of the right to silence do not warrant cessation of interrogation. Both emphasize the necessity for unequivocal invocation by the suspect.

Bar Exam Note

Understanding the concept of unambiguous invocation of the right to silence is crucial for the New Hampshire bar exam, particularly in the context of criminal procedure and defendants' rights.

Practice Pointers
  • Always advise clients to clearly articulate their desire to invoke their right to silence.
  • Be aware of the differences between silence and an actual invocation of rights in the context of interrogations.
  • Prepare to argue the clarity of a suspect's statements if they claim that their rights were violated.

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