Cited by
Opinions in New Hampshire that cite Gibbs v. Helgemoe, 367 A.2d 1041.
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In re Sanborn
545 A.2d 726
N.H. 1988
State v. Gregoire, 118 N.H. 140, 143, 384 A.2d 132, 133 (1978); Gibbs v. Helgemoe, 116 N.H. 825, 827-28, 367 A.2d 1041, 1043 (1976).
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State v. Robb
484 A.2d 1130
N.H. 1984
Later changes in statutory and case law, however, gave him that right, see Gibbs v. Helgemoe, 116 N.H. 825, 367 A.2d 1041 (1976), and he was recommitted in 1977, 1979, and 1981.
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State v. Ballou
481 A.2d 260
N.H. 1984
Finally, in Gibbs v. Helgemoe, 116 N.H. 825, 367 A.2d 1041 (1976), we said that the “[e]ssential elements in a commitment hearing are the nature of the burden of proof and on whom it is imposed.” Id.
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State v. Paradis
455 A.2d 1070
N.H. 1983
Gibbs v. Helgemoe, 116 N.H. 825, 827, 367 A.2d 1041, 1042 (1977); Jackson v. *71 Indiana, 406 U.S. 715, 723-24 (1972); Baxstrom v. Herold, 383 U.S. 107, 111-12 (1966).
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Opinion of the Justices
442 A.2d 594
N.H. 1982
Previously, in Gibbs v. Helgemoe, 116 N.H. 825, *203 828-29, 367 A.2d 1041, 1043-44 (1976), we had held that a reasonable doubt standard of proof was constitutionally required in criminal recommitment hearings.
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State v. Novosel
412 A.2d 739
N.H. 1980
Anticipating this court’s decision in Gibbs v. Helgemoe, 116 N.H. 825, 367 A.2d 1041 (1976), the court ordered Novosel’s commitment reviewed in two years.
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State v. Steeves
406 A.2d 111
N.H. 1979
LAMPRON, C.J. This is an action for modification of a recommitment order entered in compliance with Gibbs v. Helgemoe, 116 N.H. 825, 367 A.2d 1041 (1976).
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Grindle v. Miller
400 A.2d 787
N.H. 1979
RSA 135-B:38; RSA 651:ll-a (Supp. 1977); see Gibbs v. Helgemoe, 116 N.H. 825, 367 A.2d 1041 (1976).
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Hudson v. Miller
399 A.2d 612
N.H. 1979
We hold that plaintiff’s current incarceration constitutes a denial of his right to equal protection of the laws under the State and Federal Constitutions because it allows for indefinite internment without automatic review.
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State v. ROBERT H. ____
393 A.2d 1387
N.H. 1978
Involuntary commitment proceedings, “whether civil or criminal,” involve a deprivation of liberty “which constitutes a grievous loss.” Gibbs v. Helgemoe, 116 N.H. 825, 828, 367 A.2d 1041, 1043 (1976), and State v. Gregoire, 118 N.H. 140, 384 A.2d 132 (1978).
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State v. Gregoire
384 A.2d 132
N.H. 1978
For the order to be renewed, another judicial hearing must be held.” In Gibbs v. Helgemoe, 116 N.H. 825, 367 A.2d 1041 (1976), we held that in a criminal re-commitment hearing the State must prove beyond a reasonable doubt that a patient’s present mental condition is such that it would be dangerous for him to be at large.
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Novosel v. Helgemoe
384 A.2d 124
N.H. 1978
State v. Gregoire, 118 N.H. 140, 384 A.2d 132 (1978), decided this day; Proctor v. Butler, 117 N.H. 927, 380 A.2d 673 (1977); see Gibbs v. Helgemoe, 116 N.H. 825, 367 A.2d 1041 (1976).
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Proctor v. Butler
380 A.2d 673
N.H. 1977
This we acknowledged when in Gibbs v. Helgemoe, 116 N.H. 825, 828, 367 A.2d 1041, 1043 (1976), we noted “It is clear that in involuntary confinement hearings, whether civil or criminal, the person involved is deprived of his liberty which constitutes a grievous loss.” The state’s principal objection to a reasonable doubt standard is that it is “unworkable and weighs the scale
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State v. Kupchun
373 A.2d 1325
N.H. 1977
This court held in Gibbs v. Helgemoe, 116 N.H. 825, 367 A.2d 1041 (1976), that such a confinement is subject to the provisions of RSA 651:11-a (Supp. 1975), which requires that a judicial hearing for its renewal be held on or before July 1,1977, or the original order of commitment shall then become null and void.