Law School Case Brief
State v. Belleville - 166 N.H. 58, 88 A.3d 918 (2014)
To prevail upon his challenge to the sufficiency of the evidence, a defendant must prove that no rational trier of fact, viewing all of the evidence and all reasonable inferences from it in the light most favorable to the State, could have found guilt beyond a reasonable doubt.
Defendant Chad Belleville's conviction stemmed from a motor vehicle accident that seriously injured the child of another motorist. The facts showed that Belleville chose to look down at a text message long enough to allow his vehicle to cross nearly three lanes of traffic into the opposite lane of travel without returning his attention to the road. At no time did he brake or take any evasive action. According to Belleville's own admission, he failed to notice any other vehicles until he struck one vehicle and went on to strike a second vehicle. After a bench trial in New Hampshire state court, Belleville was convicted of second-degree assault under RSA 631:2 (2007). Belleville appealed, alleging that the State failed to present sufficient evidence to prove that he acted recklessly.
Did the State present sufficient evidence to prove that Belleville acted recklessly?
The state supreme court affirmed Belleville's conviction. The court noted that Belleville's conduct was more than a case of momentary inattention, such as might be caused by changing a radio station or sneezing. Here, Belleville chose to divert his attention from the road to check a text message and remained so inattentive that he failed to notice that he crossed nearly three lanes of traffic and entered into the opposite lane in the face of oncoming traffic. Under such circumstances, the court could not say that a reasonable trier of fact, viewing the evidence and all reasonable inferences from it in the light most favorable to the State, could not have found that Belleville acted recklessly.
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