Cited by

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).

Accordingly, we consider them waived.

To the extent that the defendant argues that not holding oral argument “would violate his rights to due process, production of all proofs favorable, effective assistance of counsel and equal protection” under the State and Federal Constitutions, he does not develop this argument.

To the extent that the defendant makes constitutional arguments other than those arguments specifically addressed below, they are not sufficiently developed for review.

We construe his brief to argue that the trial court violated Part I, Article 14 of the State Constitution and his state and federal constitutional rights to due process and equal protection by not finding that he was indigent pursuant to RSA 623-B:2, IV (2011).

Because the defendant’s due process argument is undeveloped, we decline to address it.

Likewise, although the defendant asserts that reconvening the jury constituted a violation of his “rights to due process of law and a fair trial and his double jeopardy rights, under both the Federal and State Constitutions,” he fails to adequately develop his legal argument, and, therefore, we decline to address it.

“The purpose of a bill of particulars is to protect a defendant against a second prosecution for an inadequately described offense and to enable him to prepare an intelligent defense.” Sanborn, 168 N.H. at ___, 130 A.3d at 577 (quotation omitted); see State v. Chick, 141 N.H. 503, 507 (1996) (“The State is not required to provide a bill of particulars except when necessary for the preparation of a defense or to preclude a later unconstitutional prosecution.” (quotation omitted)).

We conclude, however, that Ellis has waived her arguments that the trial court deprived her of due process because she has not adequately developed them.

Furthermore, she does not develop it.

State v. Chick, 141 N.H. 503, 504 (1996) (declining to address constitutional argument based upon “passing reference to ‘due process’ ”).

The defendant, however, does not develop this argument or explain why exhausting his peremptory challenges requires a different conclusion.

*278 In his brief, the defendant makes passing reference to “Part I, Article 15 of the New Hampshire Constitution and the Fifth, Sixth and Fourteenth Amendments to the United States Constitution.” “Because the defendant has not developed his constitutional arguments, we decline to address them.” State v. Lott, 152 N.H. 436, 443 (2005); see State v. Chick, 141 N.H. 503, 504 (1996) (defendant waived constitutional claims by failing to elaborate on them.).

Accordingly, we will overturn the trial court’s rulings only if the defendant can show that they are clearly untenable or unreasonable to the prejudice of his case.” State v. Chick, 141 N.H. 503, 504 (1996) (citations omitted).

See, e.g., State v. Chick, 141 N.H. 503, 504 (1996) (although defendant’s brief claimed violation of right to due process, claim waived where brief failed to further elaborate on argument).

As we have repeatedly stated, “[¿Judicial review is not warranted for complaints regarding adverse rulings without developed legal argument, 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 ar

To the extent the defendant believed a more specific statement of the crime was required, he could have requested a bill of particulars.

“[P]assing reference to ‘due process,’ without more, is not a substitute for valid constitutional argument.” State v. Chick, 141 N.H. 503, 504 (1996).

State v. Chick, 141 N.H. 503, 504 (1996) (passing reference to constitutional claim renders argument waived).

State v. Fernandez, 152 N.H. 233, 239 (2005); see also State v. Chick, 141 N.H. 503, 504 (1996) (passing reference to a constitutional principle is not a substitute for a valid constitutional argument and is therefore waived).

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. Blackmer, 149 N.H. 47, 49 (2003); State v. Chick, 141 N.H. 503, 504 (1996) (passing reference to constitutional claim renders it waived).

We conclude that the defendant has not demonstrated that the juror compensation scheme violates either State or federal constitutional guarantees.

An indictment is generally sufficient if it recites the language of the relevant statute; it need not specify the means by which the crime was accomplished or any other facts that are not essential elements of the crime.

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).

“[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 record demonstrates that the trial court weighed the statutory factors and properly ruled that the defendant had not met his burden of establishing necessity.

A bare, eonclusory assertion alone of the possibility of a time-based defense is insufficient to invoke the right to a bill of particulars.

State v. Chick, 141 N.H. 503, 504, 688 A.2d 553, 554 (1996); State v. Plante, 134 N.H. 456, 459, 594 A.2d 1279, 1282 (1991).

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 motion in limine was silent on the credibility issue the defendant now advances on appeal, and no objection was made to the doctor’s testimony at trial.

The defendant must show that the trial court’s ruling was “clearly untenable or unreasonable to the prejudice of his case.” State v. Chick, 141 N.H. 503, 504, 688 A.2d 553, 554 (1996).

Accordingly, we consider it waived.

We conclude, however, that the defendant’s failure to devote anything more than passing reference in his brief to retrospective laws and vested rights undér the Federal Constitution renders those federal claims waived.

Under RSA 517:13, III, a party to a felony case “may take a discovery deposition of any expert witness who may be called by the other party to testify at trial.” While the trial court has the discretion to grant or deny a deposition of a lay witness, see RSA 517:13, II (Supp. 1996); State v. Chick, 141 N.H. 503, 505, 688 A.2d 553, 554-55 (1996), it is not accorded similar discretion with expert witnesses.

Accordingly, we decline to consider this argument on appeal.