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Prior to adopting a court rule regarding joinder of criminal charges, we adopted, as a matter of common law, the ABA standards for joinder and severance of criminal offenses in State v. Ramos, 149 N.H. 118, 127 (2003).

ima facie case of racial discrimination based upon the manner in which the prosecution uses peremptory challenges, as announced in Batson v. Kentucky, 476 U.S. 79, 96- 98 (1986), had retroactive effect); Tierney, 150 N.H. at 342-45 (analyzing, for cases on direct review, whether the new constitutional rule articulating “the absolute right to sever unrelated cases,” as announced in State v. Ramos, 149 N.H. 118, 127 (2003), had retroactive effect).

Ct. R. 51(A)(1)(b); see also State v. Ramos, 149 N.H. 118, 129 (2003) (Dalianis, J., dissenting).

portion” of its closing argument and the evidence was not “lengthy, comprehensive, or directly linked to a determination of the guilt or innocence of the defendant” (quotation omitted)), and State v. Hennessey, 142 N.H. 149, 159 (1997) (harmless error where the State did not “call particular attention to [the disputed evidence] in closing argument”), abrogated on other grounds by State v. Ramos, 149 N.H. 118 (2003), and State v. Quintero, 162 N.H. 526 (2011), with State v. Pelkey, 145 N.H. 133,

no single factor is wholly determinative,” State v. Duran, 158 N.H. 146, 154 (2008), because “the doctrine of stare decisis is not one to be either rigidly applied or blindly followed.” State v. Ramos, 149 N.H. 118, 127 (2003) (quotation omitted).

Historically, the decision to join multiple charges has been a discretionary matter left to the trial court.

‘We will uphold the trial court’s decision not to sever cases unless we conclude that the decision constitutes an unsustainable exercise of discre *336 tion.” State v. Ramos, 149 N.H. 118, 120 (2003).

We will uphold the trial court’s decision to join the charges unless we conclude that the decision constitutes an unsustainable exercise of discretion.

Following sentencing, the defendant appealed his convictions to this court, arguing that the charges against him should have been severed under State v. Ramos, 149 N.H. 118 (2003), because they arose from three “unrelated” courses of conduct.

We will uphold the trial court’s decision not to sever the charges unless we conclude that the decision constitutes an unsustainable exercise of discretion.

The stability of the law does not require the continuance of recognized error.” State v. Ramos, 149 N.H. 118, 127-28 (2003) (quotation omitted).

In support of its motions to join the offenses for trial, the State argued that they were based upon a common plan under Stale v. Ramos, 149 N.H. 118 (2003).

The defendant observes that, in State v. Ramos, 149 N.H. 118, 127-28 (2004), the court adopted a “new, severance-friendly standard in criminal cases”; he urges the court to apply this standard to civil cases.

The defendant argued that the offenses underlying the three sets of charges were “unrelated,” so he was entitled to severance as a matter of right under State v. Ramos, 149 N.H. 118 (2003).

In March 2003, the State moved to consolidate the seventeen indictments, citing our decision in State v. Ramos, 149 N.H. 118 (2003).

We will uphold the trial court’s decision not to sever the charges unless we conclude that the decision constitutes an unsustainable exercise of discretion.

On appeal, the State concedes that the charges against the defendant were unrelated and, therefore, under State v. Ramos, 149 N.H. 118 (2003), the defendant was entitled to severance of the unrelated charges.

The defendant appeals his conviction and argues that this case must be decided under the standards for severance recently set out in State v. Ramos, 149 N.H. 118 (2003).

The defendant argues that the trial court erred by: (1) denying his motion to sever “the unrelated sets of charges” involving both boys, pursuant to State v. Ramos, 149 N.H. 118 (2003); (2) preventing him from presenting “evidence about his character for truthfulness,” under New Hampshire Rule of Evidence 608(a); and (3) allowing the State to present expert testimony through a lay witness.

We will uphold the trial court’s decision not to sever cases unless we conclude that the decision constitutes an unsustainable exercise of discretion.