State of New Hampshire v. James F. Houghton

Following a jury trial in Superior Court (Smukler, J.), the defendant, James F. Houghton, was convicted on 23 charges of possession of child pornography. See RSA 649-A:3, 1(a) (Supp. 2014). On appeal, the defendant argues that the evidence at trial was insufficient to prove beyond a reasonable doubt that; (1) 15 of the charges involved depictions of individuals under the age of 18; and (2) one of the charges involved a depiction of “sexually explicit conduct.” Id. We conclude that, as to nine of the charges, the evidence was insufficient to prove beyond a reasonable doubt that the individuals…