A Concord man accused of fatally shooting his half-brother in the back of the neck believed that his sibling had “ratted” on him to Concord police in a separate investigation, according to a police document in the case. 

Jesse Sullivan, 32, is charged with first-degree murder in the Jan. 16 killing of 19-year-old Zackary Sullivan.

The document – a probable cause statement to search an iPad recovered at the scene – provides new details on the nature of the shooting and a potential motive. It was unsealed in response to a request filed by the Concord Monitor.

Twenty-four-year-old Rory Sullivan was driving his brothers to go snow plowing in Concord on a Tuesday evening when Jesse – in the backseat – shot Zackary – in the passenger seat – from behind at point-blank range, Rory told police.

Rory and Zackary are full brothers, according to Michael Garrity, a spokesman for the New Hampshire Attorney General’s Office, while Jesse is a half-brother to both of them. All three were residents of Concord.

Rory told police that they were driving down Garvins Falls Road toward Manchester Street when he heard a loud “pop”, and then looked over to see Zackary’s head had dropped. 

“What the f--- did you just do?” Rory said he yelled at Jesse. The elder brother responded, “uh, he’s just sleeping bro,” according to the affidavit, before jumping out of Rory’s pickup truck and fleeing the area.

Rory told police he proceeded to drive to the Dunkin’ Donuts on Manchester Street before calling the police. Concord police arrived at approximately 7:10 p.m. and observed Zackary lying on his back on the ground outside the passenger side of Rory’s truck.

Police discovered a Kimber 9mm handgun between Zackary’s button-down shirt and undershirt. Jesse was charged with falsifying evidence with respect to a Walther P22 pistol. It was not clear whether one of the two guns was misidentified in documents, or whether two separate guns were recovered. Police have not publicly identified the suspected murder weapon.

Jesse has a criminal record that dates back to 2008 and includes more than a dozen arrests, according to court records. Because of his status as a felon, he was prohibited from possessing a gun at the time of the shooting. He has also been convicted of assault while incarcerated and has been accused of domestic violence by two different people, including a family member, according to court records.

Concord police referred questions about the separate investigation that Rory referenced to the Attorney General’s Office. Garrity, the department’s spokesperson, declined to comment on the nature of the “issue” the half brothers reportedly had, but according to arrest records, it appears linked to a November 2023 altercation in Concord.

Police were called to a Garvins Falls Road house on Nov. 24 in response to a report that Jesse had punched a man who lives there. A resident of the home told police that Jesse and two other men had shown up to her house and that Jesse had asked her for a hug, which she refused to give, according to an arrest warrant affidavit.

The 57-year-old woman then called for help from her daughter’s boyfriend, who was in the basement of the house. The boyfriend – who said he knew Jesse from their time as school classmates – told police that he asked the men to leave but they refused. Jesse then punched the boyfriend in the face, and the other two men assaulted him too, the victim told police. The three men then departed the house.

Later, Concord police stopped a vehicle matching the description of the one at Garvins Falls Road, which Zackary was identified as driving and owning. 

An arrest warrant for Jesse was issued the day of the incident, which was executed when he was arrested hours after the shooting. A warrant was also issued for the other man present but not for Zackary, according to Concord Police Deputy Chief John Thomas.

In court Monday, Jesse’s trial was scheduled for June 2, 2025. Jesse waived his right to be arraigned and did not appear in court.

“Mr. Sullivan has entered pleas of not guilty to the pending indictments and he enjoys the presumption of innocence afforded to him under both the state and federal constitutions,” Jesse’s attorney, Jeremy Clemans, said in a statement.

Garrity declined to comment on the case or the details of the affidavit.

Concord District Court Judge Sarah D. Christie denied a separate Concord Monitor motion to unseal the arrest warrant and affidavit and any search warrants in the homicide investigation. The judge did not provide any rationale for her denial of the motion, which was not opposed by either the prosecution or defense in the case.

Jeremy Margolis can be contacted at jmargolis@cmonitor.com.