Cited by

State v. Blackmer, 149 N.H. 47, 49 (2003) (“[I]n the realm of appellate review, a mere laundry list of complaints regarding adverse rulings by the trial court, without developed legal argument, is insufficient to warrant judicial review.”) (quotation omitted); see also Keenan v. Fearon, 130 N.H. 494, 499 (1988) (observing that “off-hand invocations” of constitutional rights supported by neither argument nor authority warrant no extended consideration).

State v. Blackmer, 149 N.H. 47, 49 (2003) (“[I]n the realm of appellate review, a mere laundry list of complaints regarding adverse rulings by the trial court, without developed legal argument, is insufficient to warrant judicial review.”) (quotation omitted); see also Keenan v. Fearon, 130 N.H. 494, 499 (1988) (observing that “off-hand invocations” of constitutional rights supported by neither argument nor authority warrant no extended consideration).

Keenan v. Fearon, 130 N.H. 494, 499 (1988) (explaining that “off-hand invocations” of constitutional rights supported by neither argument nor authority “warrant[] no extended consideration”).

State v. Chick, 141 N.H. 503, 504 (1996) (passing reference to constitutional claim renders argument waived); Keenan v. Fearon, 130 N.H. 494, 499 (1988) (“off-hand invocations” of constitutional rights supported by neither argument nor authority warrant no extended consideration).

Keenan v. Fearon, 130 N.H. 494, 499 (1988) (explaining that “off-hand invocations” of the State Constitution supported by neither argument nor authority warrant no extended consideration); Vogel v. Vogel, 137 N.H. 321, 322 (1993).

Sabinson v. Trustees of Dartmouth College, 160 N.H. 452, 459 (2010); Keenan v. Fearon, 130 N.H. 494, 499 (1988) (“off-hand invocations” of constitutional rights supported by neither argument nor authority warrant no extended consideration).

Sumner v. N.H. Sec’y of State, 168 N.H. 667, 672 (2016) (citing Keenan v. Fearon, 130 N.H. 494, 499 (1988)).

As previously noted, the trial court found “this action to be frivolous and filed for the purpose of harassing the defendants as a result of their eviction against [the plaintiff’s] father.” These findings, which are supported by the record, amount to a finding of bad faith and are sufficient to support the court’s award of attorney’s fees.

To the extent the petitioners are arguing that the statute and regulations are unconstitutionally vague, this argument is insufficiently developed for appellate review.

Keenan v. Fearon, 130 N.H. 494, 499 (1988) (explaining that “off-hand invocations” of constitutional rights supported by neither argument nor authority warrant no extended consideration).

“[I]n the realm of appellate review, a mere laundry list of 4 complaints regarding adverse rulings by the trial court, without developed legal argument, is insufficient to warrant judicial review.” Douglas v. Douglas, 143 N.H. 419, 429 (1999) (citation omitted); see Keenan v. Fearon, 130 N.H. 494, 499 (1988) (explaining that “off-hand invocations” of constitutional rights supported by neither argument nor authority warrant no extended consideration).

Keenan v. Fearon, 130 N.H. 494, 499 (1988) (explaining that “off-hand invocations” of constitutional rights “supported neither by argument nor by authority.

The trial court additionally awarded attorney’s fees to Jennifer, Cieslik, and Shute, finding that the claims against them, as pleaded, lacked any reasonable basis in law or fact.

Keenan v. Fearon, 130 N.H. 494, 499 (1988) (“off-hand invocations” of constitutional rights supported by neither argument nor authority warrant no extended consideration).

“[I]n the realm of appellate review, a mere laundry list of complaints regarding adverse rulings by the trial court, without developed legal argument, is insufficient to warrant judicial review.” Douglas v. Douglas, 143 N.H. 419, 429 (1999) (citation omitted); see Keenan v. Fearon, 130 N.H. 494, 499 (1988) (“off-hand invocations” of constitutional rights supported by neither argument nor authority warrant no extended consideration).

Second, “in the realm of appellate review, a mere laundry list of complaints regarding adverse rulings by the trial court, without developed legal argument, is insufficient to warrant judicial review.” Douglas v. Douglas, 143 N.H. 419, 429 (1999) (citation omitted); see Keenan v. Fearon, 130 N.H. 494, 499 (1988) (“off-hand invocations” of constitutional rights supported by neither argument nor authority warrant no extended consideration).

Keenan v. Fearon, 130 N.H. 494, 499 (1988) (“[O]ff-hand invocations of the State Constitution [that] are supported neither by argument nor by authority.

Although, on appeal, the defendant cites various constitutional provisions, such “offhand invocations” of constitutional rights supported by neither argument nor authority warrant no extended consideration.

warrant[ ] no extended consideration.” Keenan v. Fearon, 130 N.H. 494, 499 (1988).

Black’s Law Dictionary 1701 (9th ed. 2009) (defining “vexatious” as “without reasonable or probable cause or excuse; harassing; annoying”); cf. Keenan v. Fearon, 130 N.H. 494, 502 (1988) (explaining that “we have recognized a.

ument, and neither passing reference to constitutional claims nor off-hand invocations of constitutional rights without support by legal argument or authority warrants extended consideration.” Appeal of Omega Entm’t, 156 N.H. 282, 287 (2007); State v. Chick, 141 N.H. 503, 504 (1996) (explaining that a mere passing reference to a constitutional claim renders the argument waived); Keenan v. Fearon, 130 N.H. 494, 499 (1988) (stating that “off-hand invocations” of constitutional rights supported by

warrant[] no extended consideration.” Keenan v. Fearon, 130 N.H. 494, 499 (1988).

In the Matter of Thayer and Thayer, 146 N.H. 342, 347 (2001); Keenan v. Fearon, 130 N.H. 494, 499 (1988) (“off-hand invocations” of constitutional rights supported by neither argument nor authority warrant no extended consideration).

“[I]n the realm of appellate review, a mere laundry list of complaints regarding adverse rulings by the trial court, without developed legal argument, is insufficient to warrant judicial review.” Douglas v. Douglas, 143 N.H. 419, 429 (1999) (citation omitted); see Keenan v. Fearon, 130 N.H. 494, 499 (1988) (“offhand invocations” of constitutional rights supported by neither argument nor authority warrant no extended consideration).

Thus, this is hardly a case where “off-hand invocations of [constitutional rights] are supported by neither argument nor by authority.” Keenan v. Fearon, 130 N.H. 494, 499 (1988).

State v. Chick, 141 N.H. 503, 504 (1996) (passing reference to constitutional claim renders argument waived); Keenan v. Fearon, 130 N.H. 494, 499 (1988) (“off-hand invocations” of constitutional rights supported by neither argument nor authority warrant no extended consideration).

State v. Chick, 141 N.H. 503, 504 (1996); Keenan v. Fearon, 130 N.H. 494, 499 (1988) (“off-hand” invocations of constitutional rights supported by neither argument nor authority warrant no extended consideration).

State v. Chick, 141 N.H. 503, 504 (1996) (passing reference to constitutional claim renders argument waived); Keenan v. Fearon, 130 N.H. 494, 499 (1988) (“off-hand invocations” of constitutional rights supported by neither argument nor authority warrant no extended consideration).

Keenan v. Fearon, 130 N.H. 494, 499 (1988) (“off-hand invocations” of constitutional rights supported by neither argument nor authority warrant no extended consideration).

State v. Chick, 141 N.H. *249 503, 504 (1996) (passing reference to constitutional claim renders argument waived); Keenan v. Fearon, 130 N.H. 494, 499 (1988) (“off-hand invocations” of constitutional rights supported by neither argument nor authority warrant no extended consideration).

“[A] mere laundry list of complaints regarding adverse rulings by the trial court, without developed legal argument, is insufficient to warrant judicial review.” Douglas v. Douglas, 143 N.H. 419, 429 (1999) (citation omitted); see also State v. Chick, 141 N.H. 503, 504 (1996) (passing reference to constitutional claim renders argument waived); Keenan v. Fearon, 130 N.H. 494, 499 (1988) (“off-hand invocations” of constitutional rights supported by neither argument nor authority warrant no extende

The question is whether" litigation was “unnecessary” because the claim was meritless.

Indeed, because a “fee award does not require proof of a subjectively intended injury, but may rest on the *267 objectively gratuitous character of the litigation,” Keenan v. Fearon, 130 N.H. 494, 502, 543 A.2d 1379, 1384 (1988), probing the party’s subjective intent through direct and cross-examination may be unnecessary.

State v. Chick, 141 N.H. 503, 504, 688 A.2d 553, 554 (1996) (insufficient elaboration of constitutional claim renders argument waived); Keenan v. Fearon, 130 N.H. 494, 499, 543 A.2d 1379, 1382 (1988) (“offhand invocations” of constitutional rights supported by neither argument nor authority warrant no extended discussion).

The court granted the motion, concluding that there was no reasonable basis in facts provable by evidence for the plaintiff’s claims, see Keenan v. Fearon, 130 N.H. 494, 502, 543 A.2d 1379, 1383 (1988), and that the plaintiff brought the case “in bad faith and for vexatious purposes” since the defendant was forced to litigate against the meritless claims to enjoy the custody to which she was entitled.

The court denied the plaintiff’s request for attorney’s fees, reasoning that the city did not interfere with a clearly defined legal right *315 of the plaintiff, see Keenan v. Fearon, 130 N.H. 494, 501-02, 543 A.2d 1379, 1383 (1988), because “[t]here is no directly relevant precedent in New Hampshire clearly defining a municipality’s authority to license businesses that sell liquor.” This appeal by the city and cross-appeal by the plaintiff followed.

The award of fees is justified as “compensation for those who are forced to litigate against an opponent whose position is patently unreasonable,” Keenan v. Fearon, 130 N.H. 494, 502, 543 A.2d 1379, 1383 (1988), *765 without “any reasonable basis in the facts...

Where a party is forced to seek judicial assistance to secure a clearly defined right, a court may award attorney’s fees to the prevailing party if bad faith on the part of the losing party is established.

Apart from vague references in his brief to “due process and equal protection rights under the New Hampshire Constitution,” the defendant does not mount a constitutional attack on appeal, and we therefore do not undertake a constitutional analysis.

We conclude that the plaintiff’s abuse of process allegation was “without any reasonable basis in the facts provable by evidence, or any reasonable claim in the law as it is, or as it might arguably be held to be.” Keenan v. Fearon, 130 N.H. 494, 502, 543 A.2d 1379, 1383 (1988).

Even though the district court is not a constitutional court and does not have a general grant of equitable power, see Keenan v. Fearon, 130 N.H. 494, 502, 543 A.2d 1379, 1383-84 (1988) (power to award sanctions “rests...

Although many of these theories ultimately proved unsuccessful, overall the plaintiffs’ case did not lack “any reasonable basis in the facts provable by evidence, or any reasonable claim in the law as it is, or as it might arguably be held to be.” Keenan v. Fearon, 130 N.H. 494, 502, 543 A.2d 1379, 1383 (1988); see also Adams v. Bradshaw, 135 N.H. 7, 17-18, 599 A.2d 481, 488 (1991); cert.

We infer that the trial court relied on the exception for parties who are “forced to litigate against an opponent whose position is patently unreasonable.” Keenan v. Fearon, 130 N.H. 494, 502, 543 A.2d 1379, 1383 (1988); see also St.

The superior court denied the motions relying on our decision in Keenan v. Fearon, 130 N.H. 494, 502, 543 A.2d 1379, 1383 (1988), and its power “to award counsel fees in any action commenced, prolonged, required or defended without any reasonable basis in facts provable by evidence, or any reasonable claim in the law as it is, or as it might arguably be held to be.” On appeal, the Francoeurs argue that their de

Germain v. Adams, 117 N.H. 659, 662, 377 A.2d 620, 623 (1977); as “compensation for those who are forced to litigate in order to enjoy what a court has already decreed,” Keenan v. Fearon, 130 N.H. 494, 502, 543 A.2d 1379, 1383 (1988); and “for those who are forced to litigate against an opponent whose position is patently unreasonable,” id.

That Burke listed these factors without elaboration makes extensive consideration of them unnecessary.

Germain v. Adams, 117 N.H. 659, 662, 377 A.2d 620, 623 (1977), and cases in which parties “are forced to litigate against an opponent whose position is patently unreasonable.” Keenan v. Fearon, 130 N.H. 494, 502, 543 A.2d 1379, 1383 (1988).

Keenan v. Fearon, 130 N.H. 494, 499, 543 A.2d 1379, 1382 (1988) (“glancing character” of defendant’s treatment of claim “warrants no extended consideration”).

As we stated in Keenan v. Fearon, 130 N.H. 494, 502, 543 A.2d 1379, 1383 (1988), the award of attorney’s fees is appropriate in “any action commenced, prolonged, required or defended without any rea *505 sonable basis in the facts provable by evidence, or any reasonable claim in the law as it is, or as it might arguably be held to be.” Id.

Germain v. Adams, 117 N.H. 659, 662, 377 A.2d 620, 623 (1977); and as “compensation for those who are forced to litigate in order to enjoy what a court has already decreed” and for those who are “forced to litigate against an opponent whose position is patently unreasonable,” Keenan v. Fearon, 130 N.H. 494, 502, 543 A.2d 1379, 1383 (1988).