State of New Hampshire v. Stephen Stangle

After a jury trial in Superior Court (Bomstein, J.), the defendant, Stephen Stangle, was convicted on one count of theft by deception. RSA 637:4 (2007). On appeal, the defendant argues that the trial court erred in admitting a surveillance video without proper authentication. We affirm.

The following facts are drawn from the record or are otherwise undisputed. In January 2012, while shopping in a store in Woodsville, the defendant placed a vacuum cleaner in his shopping cart, passed through an unattended register line without paying, and proceeded to the customer service area to “return” the…