New Hampshire v. Woodbury

Defendant Jonathan Woodbury appealed his convictions and sentences on one count of falsifying physical evidence, and two counts of assault by a prisoner. In December 2016, defendant was an inmate at the Northern New Hampshire Correctional Facility who got involved in a physical altercation with Matthew Moriarty, another inmate at the facility. At the time of the incident, Moriarty was fighting with his cellmate, Terrence Hartley, and had sustained severe injuries. While most of the dispute between Hartley and Moriarty occurred within their cell, at one point during the fight, Moriarty was outside of the cell when the cell door closed, locking him outside. After attempting to get back inside, Moriarty, while bleeding from his face, spit at Hartley through an opening in the cell door. Defendant, who was watching from the common area of the cellblock, came up behind Moriarty and struck him with his fist on the side of the face. Moriarty then swung at and struck defendant, who continued the altercation, twice more striking Moriarty with his fist. Following this exchange, defendant, with the help of another inmate, mopped up Moriarty’s blood from the floor and tables in the common area. Meanwhile, Moriarty went into the bathroom to clean blood from his face. Realizing that he was struggling to breathe, he exited the bathroom to press a button on a callbox located in the common area. This action alerted correctional officers that an incident had occurred and a response team was sent to the cellblock. On appeal, defendant challenged: (1) the sufficiency of the evidence to support his conviction of falsifying physical evidence; (2) the trial court’s denial of his jury instruction interpreting language in RSA 641:6, I; (3) the trial court’s imposition of multiple sentences on the assault convictions; and (4) the trial court’s failure to sua sponte instruct the jury on the defense of mutual combat. Finding no reversible error, the New Hampshire Supreme Court affirmed. View "New Hampshire v. Woodbury" on Justia Law