Cited by

Revocable Trust v. Cardone, 160 N.H. 521, 526 (2010) (“Judicial review is not warranted for complaints regarding adverse rulings without developed legal argument, and neither passing reference to constitutional claims nor casual invocations of constitutional rights without support by legal argument or authority warrants extended consideration.”); see also In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self-represented litigants are bound by the same procedural rules that gover

In the Matter of Birmingham & Birmingham, 154 N.H. 51, 58 (2006); RSA 458:19-aa, I-a (Supp. 2024) (“If contested, an alimony modification shall not be effective prior to the date that the notice of the petition for modification was given to the other party.”).

Mgmt., 151 N.H. 248, 250 (2004); see also In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self-represented litigants are bound by the same procedural rules that govern parties represented by counsel).

Ct. R. 16(3)(b) (“After each statement of a question presented, counsel shall make specific reference to the volume and page of the transcript where the issue was raised and where an objection was made, or to the pleading which raised the issue.”); see also In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self-represented litigants are bound by the same procedural rules that govern parties represented by counsel).

Ct. R. 13 (“The moving party shall be responsible for ensuring that all or such portions of the record relevant and necessary for the court to decide the questions of law presented by the case are in fact provided to the supreme court.”); In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self-represented litigants are bound by the same procedural rules that govern parties represented by counsel).

id.; In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56-57 (2006) (noting that such rules are not relaxed for self-represented parties).

Thompson v. D’Errico, 163 N.H. 20, 22 (2011); see also In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self-represented litigants are bound by the same procedural rules that govern parties represented by counsel).

In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56-57 (2006).

In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56-57 (2006).

State v. Winstead, 150 N.H. 244, 246 (2003); see also In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self-represented litigants are bound by the same procedural rules that govern parties represented by counsel).

Ct. R. 13; see also In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self-represented litigants are bound by the same procedural rules that govern parties represented by counsel).

id.; see also In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self-represented litigants are bound by the same procedural rules that govern parties represented by counsel).

“It is well established that courts may grant reformation in proper cases where the instrument fails to express the intentions that the parties had in making the contract.” In the Matter of Lemieux & Lemieux, 157 N.H. 370, 373 (2008); see also In the Matter of Birmingham & Birmingham, 154 N.H. 51, 57 (2006) (explaining that a court may modify or amend a final property distribution upon a showing that the property distribution is invalid due to fraud, undue influence, deceit, misrepresentation, o

Mgmt., 151 N.H. 248, 250 (2004); see also In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self-represented litigants are bound by the same procedural rules that govern parties represented by counsel).

Ct. R. 13; see also In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self-represented litigants are bound by the same procedural rules that govern parties represented by counsel).

In the Matter of Arvenitis & Arvenitis, 152 N.H. 653, 654 (2005); In the Matter of Birmingham & Birmingham, 154 N.H. 51, 57 (2006).

RSA 526:1 provides: “A new trial may be granted in any case when through accident, mistake or misfortune justice has not been done and a further hearing would be equitable.” “Whether accident, mistake, or misfortune occurred is determined by the trier of fact, and its finding will be conclusive unless it is unsupported by the evidence.” In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006).

Panas v. Harakis & K-Mart Corp., 129 N.H. 591, 617-18 (1987); see also In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self-represented litigants are bound by the same procedural rules that govern parties represented by counsel).

trial may be granted in any case when through accident, mistake or misfortune justice has not been done and a further hearing would be equitable.” “Whether accident, mistake, or misfortune occurred is determined by the trier of fact, and its finding will be conclusive unless it is unsupported by the evidence.” In the Matter of 3 Birmingham & Birmingham, 154 N.H. 51, 56 (2006).

Bean v. Red Oak Property Mgmt., Inc., 151 N.H. 248, 250 (2004); see also In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self-represented litigants are bound by the same procedural rules that govern parties represented by counsel).

In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56-57 (2006).

Ct. R. 15; see also In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self-represented litigants are bound by the same procedural rules that govern parties represented by counsel).

In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006).

He further contends that, because a trial court has “no discretion to modify any child support order beyond the date of ‘notice’ to” the opposing party, In the Matter of Birmingham & Birmingham, 154 N.H. 51, 58 (2006) (quotation omitted), the trial court lacked authority to “order[] that the new amount of child support would be owed retroactively to the beginning of the prior calendar year.” Husband’s arguments are misplaced because the escalation clause is not a modification of a support order

Blagbrough Family Realty Trust v. A & T Forest Prods., 155 N.H. 29, 35 (2007) (“Where a party fails to demonstrate that it raised an issue before the trial court, the issue is not preserved for our review.”); In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (observing that self- represented litigants are bound by the same procedural rules that govern parties represented by counsel).1 Next, we consider the tenants’ argument that the trial court erred when it found that they had no

Ct. R. 13; see also In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self-represented litigants are bound by the same procedural rules that govern parties represented by counsel).

In the Matter of Birmingham & Birmingham, 154 N.H. 51, 55 (2006).

Moreover, it is well-settled that a trial court may modify both alimony and child support retroactively to the date that the opposing party receives formal notice of the pleading seeking modification.1 RSA 458-C:7, II; see In the Matter of Doherty & Doherty, 168 N.H. 694, 704 (2016); In the Matter of Birmingham & Birmingham, 154 N.H. 51, 58 (2006).

Such a property distribution will not be modified unless the complaining party shows that the distribution is invalid due to fraud, undue influence, deceit, misrepresentation, or mutual mistake.” In the Matter of Birmingham & Birmingham, 154 N.H. 51, 57 (2006) (quotations, citation, and brackets omitted).

Mgmt., 151 N.H. 248, 250-51 (2004); see also In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self-represented litigants are bound by the same procedural rules that govern parties represented by counsel).

Mgmt., 151 N.H. 248, 250 (2004) (parties may not have judicial review of matters not raised in the trial court); see also In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self-represented litigants are bound by the same procedural rules that govern parties represented by counsel).

In the Matter of Birmingham & Birmingham, 154 N.H. 51, 55 (2006).

Mgmt., 151 N.H. 248, 250-51 (2004), and warrant no further discussion, see Vogel v. Vogel, 137 N.H. 321, 322 (1993); see also In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self-represented litigants are bound by the same procedural rules that govern parties represented by counsel).

In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56-57 (2006).

In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56–57 (2006).

In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56-57 (2006).

Moreover, although the mother is correct that self-represented parties are bound by the same rules that govern parties represented by counsel, see In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006), parties represented by counsel are generally bound by their attorneys’ actions, see Paras v. Portsmouth, 115 N.H. 63, 67 (1975).

In the Matter of Birmingham & Birmingham, 154 N.H. 51, 55 (2006).

In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56-57 (2006).

In the Matter of Birmingham & Birmingham, 154 N.H. 51, 57 (2006).

Ct. R. 27 (computation of time); see also In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self-represented litigants are bound by the same procedural rules that govern parties represented by counsel).

Mgmt., 151 N.H. 248, 250-51 (2004) (noting that it is the appellant’s burden to provide a record sufficient to address his issues on appeal); see also In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (noting that self-represented litigants are bound by the same procedural rules that govern parties represented by counsel).

Even if we assume that this argument has been preserved for appellate review, but see State v. Blackmer, 149 N.H. 47, 48 (2003) (supreme court will not consider any issue not raised before trial court); In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self-represented parties bound by same procedural rules that govern parties represented by counsel), we find it unpersuasive.

In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56-57 (2006).

Mgmt., 151 N.H. 248, 250 (2004), that they are insufficiently developed, see State v. Blackmer, 149 N.H. 47, 49 (2003), and that they warrant no further consideration, see Vogel v. Vogel, 137 N.H. 321, 322 (1993); see also In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self- represented litigants are bound by the same procedural rules that govern parties represented by counsel).

In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56-57 (2006).

Under our case law, self- represented parties “are bound by the same procedural rules that govern 6 parties represented by counsel.” In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006).

Coyle v. Battles, 147 N.H. 98, 100 (2001) (on appeal, appellant has burden to show error); see also In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self-represented litigants are bound by the same procedural rules that govern parties represented by counsel).

In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006) (self-represented parties bound by same procedural rules as those who are represented by counsel).

In the Matter of Birmingham & Birmingham, 154 N.H. 51, 56 (2006).