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[¶14] We have construed “authority” under RSA 632-A:2, I(k) to mean the “power to require and receive submission: the right to expect obedience: superiority derived from a status that carries with it the right to command and give final decisions.” State v. Fortier, 146 N.H. 784, 794 (2001) (quotation and citation omitted).

State v. Mouser, 168 N.H. 19, 26 (2015); see also State v. Fortier, 146 N.H. 784, 788 (2001) (noting that preservation rule allows trial court to correct errors “as they occur”).

“The essential culpable act, the actus reus, is the pattern itself, that is, the occurrence of more than one sexual assault over a period of time.” State v. Fortier, 146 N.H. 784, 791 (2001).

[k]nowingly or recklessly causes serious bodily injury to a person under 13 years of age.” “It is a matter of fundamental criminal law that ‘[a] person is not guilty of an offense unless his criminal liability is based on conduct that includes a voluntary act or the voluntary omission to perform an act of which he is physically capable.’” State v. Fortier, 146 N.H. 784, 797 (2001) (quoting RSA 626:1, I (2016)) (emphasis added).

State v. Fortier, 146 N.H. 784, 791 (2001) (stating that the “essential culpable act, the actus reus” of pattern AFSA “is the pattern itself, that is, the occurrence of more than one sexual assault over a period of time”).

In State v. Fortier, we rejected the argument that the trial court violated the defendant’s right to be free from double jeopardy by sentencing him on convictions for discrete acts of sexual assault and pattern AFSA convictions, which involved the same victims, during common time periods.

To the extent that the defendant attempts to assert a distinct and additional argument concerning his right “to present a complete defense,” we decline to address it because the argument was not sufficiently developed for appellate review.

to preserve this issue for appeal because he “initially argued below in general terms, without citing to any specific authority, that his Fourth Amendment rights were violated because the officers conducted the search without first obtaining his consent.” We acknowledge that “[ijssues must be properly presented to the trial court in order to preserve them for appellate review.” State v. Fortier, 146 N.H. 784, 788 (2001).

To the extent that the defendant implied at oral argument that the process he received at the deferred sentence hearing was constitutionally infirm, he has not briefed this argument, and we deem it waived.

Contrary to his assertions, the individual acts of sexual contact underlying the pattern do not constitute elements of the pattern crime, and, therefore, need not be alleged.

These young victims may have no practical way of recollecting, reconstructing, distinguishing or identifying by specific incidents or dates all or even any of the acts of sexual assault.” State v. Fortier, 146 N.H. 784, 790-91 (2001) (quotation and citations omitted).

The jury is presumed to follow the instructions given by the trial court.

s motion to quash, the defendant further argued that “the special circumstances where the State may attempt to ‘simultaneously pursue convictions for a pattern sexual assault under RSA 632-A:2, III and for sexual assaults under RSA 632~A:2 or:3 for acts perpetrated against the same victim during a common period of time’ require the additional protections not found necessary in [State v. Fortier, 146 N.H. 784 (2001)].” The trial court denied both of the defendant’s motions.

To succeed on a sufficiency of the evidence claim, a defendant must show that, viewing the evidence in the light most favorable to the State, no rational trier of fact could have found guilt beyond a reasonable doubt.

In New Hampshire, both constitutional and statutory law afford criminal defendants the right to jury unanimity.

*465 The State’s initial response is that the defendant raised this issue only with respect to the indictment alleging abuse of Jennifer, and therefore the argument is not preserved for appeal with respect to the other two abuse indictments.

The defendant contends that the court’s instructions on burden of proof, negligence and proximate cause were “lost on the jury.” We presume that jurors follow the court’s instructions, however.

Our preservation rule requires that issues be raised at the trial court to preserve them for appellate review.

The defendant did not object to this instruction as either improper or untimely.

State v. Fortier, 146 N.H. 784, 792 (2001) (arguments not briefed are deemed waived); State v. Natalcolon, 140 N.H. 689, 691 (1996).

Finding no Bruton error, we apply the general rule that jurors follow instructions.

Further, the trial court properly confined the alcohol and drug evidence to the question of the defendant’s plan in its limiting instruction, and we presume jurors follow instructions.

We recognize that we have previously held that “[t]he focus of the pattern statute is to criminalize a continuing course of sexual assaults, not isolated instances.” State v. Fortier, 146 N.H. 784, 791 (2001).