Cited by

Lower Village Hydroelectric Assocs., 147 N.H. at 77, 782 A.2d 897; see also State v. Vashaw, 113 N.H. 636, 637-38, 312 A.2d 692 (1973) ("The underlying policy of this prohibition is to prevent the legislature from interfering with the expectations of persons as to the legal significance of their actions taken prior to the enactment of a law.").

Lower Village Hydroelectric Assocs., 147 N.H. at 77; see also State v. Vashaw, 113 N.H. 636, 637-38 (1973) (“The underlying policy of this prohibition is to prevent the legislature from interfering with the expectations of persons as to the legal significance of their actions taken prior to the enactment of a law.”).

The Lodge argues that our ruling in State v. Vashaw, 113 N.H. 636 (1973), is dispositive of this case because the Lodge interprets that decision as “requiring] the commission of an offense after [the] effective date” of the challenged statute.

State v. Vashaw, 113 N.H. 636, 312 A.2d 692 (1973) (interpreting part I, article 23’s prohibition against retrospective laws made for the decision of civil causes).

ubtedly committed themselves to personal long-term obligations such as mortgages, credit cards, car payments, and the like — obligations which might go unpaid in the months that the [law] has its immediate impact.” Ass’n of Surrogates v. State of N.Y., 940 F.2d 766, 772 (2d Cir. 1991) (holding lag payroll law unconstitutional as violative of the federal contract clause); see also State v. Vashaw, 113 N.H. 636, 637-38, 312 A.2d 692, 693 (1973) (“The underlying policy of this prohibition is to pre

Co. of N.H., 130 N.H. 265, 280, 539 A.2d 263, 271 (1988) (quoting State v. Vashaw, 113 N.H. 636, 637-38, 312 A.2d 692, 693 (1973)), appeal dismissed, 488 U.S. 1035 (1989).

No such laws, therefore should be made either for the decision of civil causes, or the punishment of crimes.” *280 The underlying purpose of this article is “to prevent the legislature from interfering with the expectations of persons as to the legal significance of their actions taken prior to the enactment of a law.” State v. Vashaw, 113 N.H. 636, 638, 312 A.2d 692, 693 (1973).

We have written: “The underlying policy of this prohibition is to prevent the legislature from interfering with the expectations of persons as to the legal significance of their actions taken prior to enactment of a law.” State v. Vashaw, 113 N.H. 636, 637-38, 312 A.2d 692, 693 (1973).

e of our own cases do contain language supporting the argument that revocation is considered a safety measure rather than a penalty, see State v. Greenwood, 115 N.H. 117, 119, 335 A.2d 644, 646 (1975); State v. Bowles, 113 N.H. 571, 574, 311 A.2d 300, 302 (1973); Cedergren v. Clarke, 99 N.H. 421, 423, 112 A.2d 882, 883-84 (1955), but these cases did not directly address the point in issue here.

State v. Perreault, 113 N.H. 588, 311 A.2d 303 (1973); Stale v. Bowles, 113 N.H. 571, 311 A.2d 300 (1973); see State v. Vashaw, 113 N.H. 636, 638, 312 A.2d 692, 693 (1973).

we have already rejected a “but for” analysis as a basis to claim that the habitual offender order itself is a further penalty for the earlier convictions that justify it.

The policy underlying “this prohibition is to prevent the legislature from interfering with the expectations of persons as to the legal significance of their actions taken prior to the enactment of a law.” State v. Vashaw, 113 N.H. 636, 637-38, 312 A.2d 692, 693 (1973).

State v. Vashaw, 113 N.H. 636, 637-38, 312 A.2d 692, 693 (1973) (offenses prior to statute can be used as basis for conviction as an habitual offender); see also State v. Heald, 120 N.H. 319, 325, 414 A.2d 1288, 1291-92 (1980) (past criminal record may be a factor in determining sentence); cf. Baldasar v. Illinois, 446 U.S. 222, 223, 227-28 (198

Prohibition of retrospective laws is designed to "prevent the legislature from interfering with the expectations of persons as to the legal significance of their actions taken prior to the enactment of a law,” State v. Vashaw, 113 N.H. 636, 638, 312A.2d 692,693(1973), and to protect individuals against unjust and oppressive punishment by preventing the legislature from establishing a new rule for the punishment of an act already done.

386, 393 (1798); State v. Vashaw, 113 N.H. 636, 637, 312 A.3d 692, 693 (1973); 1 C. Antieau, Modern Constitutional Law § 5.135 (1969).

The result would be to take away or impair “ ‘vested rights, acquired [by the defendants] under existing laws.’” Pepin v. Beaulieu, 102 N.H. 84, 89, 151 A.2d 230, 235 (1959); State v. Vashaw, 113 N.H. 636, 312 A.2d 692 (1973); 2 J. Sutherland, Statutory Construction § 41.06, at 269 (4th ed. C. Sands 1972, Supp. 1974).

This same test was recently reiterated in State v. Vashaw, 113 N.H. 636, 312 A.2d 692 (1973).

The first question related to a claim of retrospective application of the habitual offenders act and defendant concedes that the issue was determined adversely to him in State v. Vashaw, 113 *9 N.H. 636, 312 A.2d 692 (1973).