Michael Addison’s death sentence for killing Manchester Police Officer Michael Briggs in 2006 is the right sentence for someone convicted of killing a cop, lawyers with the New Hampshire Department of Justice told the state Supreme Court.
Addison is trying to get his death sentence lifted, arguing that the state’s 2019 death penalty repeal makes his execution an aberrant and disproportionate punishment. But Deputy Solicitor General Samuel Garland and Assistant Attorney General Audriana Mekula say there’s nothing disproportionate in executing someone who killed a police officer or other law enforcement officer.
Mekula and Garland filed a brief with the New Hampshire Supreme Court last week, arguing that, based on other, similar cases, the death penalty is appropriate. Garland and Mekula cited recent death penalty cases in other states for comparison, as well as the cases cited in 2015 when the Supreme Court originally upheld Addison’s sentence.
“When comparing [Addison’s] case to these cases and the cases the Court relied on in 2015, the petitioner’s death sentence is not aberrational or disproportionate, and this Court should affirm his death sentence,” the prosecutors wrote.
The Briggs murder was the culmination of the violent crime spree Addison had undertaken in 2006. The convicted felon, Addison, engaged in two armed robberies with his partner in crime, Antoine Bell-Rogers, and the pair was linked to a shooting outside a Manchester apartment building the day before the murder. Manchester Police obtained arrest warrants for Addison and Bell-Rogers, and the two men were preparing to leave the state. In the hours before Briggs would die, Addison was reportedly ready for some kind of confrontation.
“A friend warned the men that the police were nearby looking for them; [Addison] and Bell-Rogers responded by declaring that they were ‘out for blood,’” a police report filed in court states.
At around 2 a.m. on Oct. 16, 2006, Briggs and his partner, Officer John Breckenridge, were on a bicycle patrol when they were called to respond to an apartment on Lake Avenue for reports of gunshots. During their interactions at the apartment building, the officers learned that Addison and Bell-Rogers had been involved.
A short time later, at around 2:45 a.m., Briggs and Breckenridge spotted Addison and Bell-Rogers walking down the Litchfield Lane alley. Briggs started following the pair, telling them to stop. Bell-Rogers stopped almost immediately, but Addison kept going down the alley. Briggs followed, continuing to tell him to stop for the police. Addison slowed down, and Briggs got closer, about an arm’s length away, when Addison suddenly turned around, holding a pistol, and shot Briggs in the head. Addison evaded other police officers and fled the state. He was later arrested in Dorchester, Mass.
If Addison is executed, New Hampshire will become the first and only state to execute an inmate after repealing its death penalty. The death penalty repeal was passed overwhelmingly by the legislature but vetoed by Gov. Chris Sununu. However, Sununu’s veto was overridden by the House and Senate with two-thirds majorities in both chambers.
In the complex and often deeply divided landscape of capital punishment in the United States, there is one area of near-universal legal consensus among death penalty states: the murder of a law enforcement officer represents a unique crime that warrants the ultimate penalty.
As of early 2026, 27 states authorize capital punishment, and in the vast majority of those states, such as Texas, Florida, Oklahoma, and Alabama, a murder conviction does not automatically lead to a death sentence. The prosecution must prove the existence of at least one statutory “aggravating factor” or “special circumstance” that elevates the crime above an ordinary murder.
The most common aggravating factor across the country is the victim’s status as a law enforcement officer, corrections officer, or firefighter engaged in official duties.
Even a deep-blue state like Oregon, which radically redefined what constitutes “aggravated murder” in 2019 to exclude killing someone while committing a robbery, kept “the premeditated murder of a law enforcement or correctional officer” on the list. (The current Oregon governor has placed a moratorium on executions.)
In recent years, a clear legislative trend has emerged in states that previously ended capital punishment. Lawmakers in states like West Virginia, Iowa, and New York have repeatedly introduced legislation seeking to reinstate the death penalty exclusively for the murder of police officers.
These “limited reinstatement” bills suggest that for many legislators and voters, the killing of a police officer is a threshold event that overrides general opposition to state-sponsored execution.
Gov. Kelly Ayotte, who prosecuted Addison for Briggs’ murder, opposed the death penalty repeal. Addison’s quest to stop his execution comes as the legislature is considering several new bills to reinstate the death penalty for capital murder convictions.