State v. Castle

Nebraska Court of Appeals·Decided July 7, 2026·No. A-25-780·Unpublished

Opinion

IN THE NEBRASKA COURT OF APPEALS

MEMORANDUM OPINION AND JUDGMENT ON APPEAL (Memorandum Web Opinion)

STATE V. CASTLE

NOTICE: THIS OPINION IS NOT DESIGNATED FOR PERMANENT PUBLICATION AND MAY NOT BE CITED EXCEPT AS PROVIDED BY NEB. CT. R. APP. P. § 2-102(E).

STATE OF NEBRASKA, APPELLEE, V.

JOSEPH C. CASTLE, APPELLANT.

Filed July 7, 2026. No. A-25-780.

Appeal from the District Court for Douglas County: TRESSA M. ALIOTH, Judge. Affirmed. Adam J. Sipple, of Sipple Law, for appellant. Michael T. Hilgers, Attorney General, and P. Christian Adamski for appellee.

RIEDMANN, Chief Judge, and MOORE and PIRTLE, Judges. RIEDMANN, Chief Judge.

I. INTRODUCTION

Joseph C. Castle appeals from his conviction of attempted first degree sexual assault of a child, in violation of Neb. Rev. Stat. §§ 28-319.01 and 28-201 (Reissue 2016), following a jury trial in the district court for Douglas County. For the reasons stated herein, we affirm.

II. BACKGROUND

The child, L.R., was born March 2019. Castle, born June 1984, was friends with L.R.’s mother, Michaela R.

In October 2023, Castle invited Michaela to bring L.R. to swim at a hotel where he was staying. Michaela agreed and brought L.R. to the hotel, but she later left. L.R. stayed there alone with Castle. L.R. was not toilet trained, and while Michaela was gone, she “pooped in [her] pants.” Castle changed L.R.’s “Pull-Up” but he was upset with her for having an accident.

In January 2024, L.R. was removed from Michaela’s care for reasons unrelated to this case and was placed with her aunt and uncle. In February, L.R.’s aunt, Amber S., put her in therapy to help her toilet train and adjust to her new living situation.

In March 2024, L.R. told Amber that Castle had hurt her in a hotel room after she had “pooped her pants.” Amber asked where Castle had hurt her and L.R. pointed to her vagina. Around that same time, L.R. made a similar statement to another child in her preschool class, which prompted a report being made to the Department of Health and Human Services (DHHS).

Amber was eventually directed to take L.R. to a child advocacy center, Project Harmony, which provides services for families and children regarding allegations of abuse and neglect. L.R. was seen at Project Harmony in April 2024.

A forensic interview was conducted at Project Harmony, during which L.R. stated that Castle had “done something bad” to her. She clarified that he had hurt her by touching her “private” part with his finger multiple times while changing her diaper at the hotel. A medical examination of L.R. was also performed by a nurse practitioner. L.R. told the nurse practitioner that Castle only touched the outside of her vagina.

Castle was eventually charged by information with one count of attempted first degree sexual assault of a child under §§ 28-319.01 and 28-201. He pled not guilty to the charge and a jury trial was held over the span of multiple days in July 2025. Additional necessary facts will be included in our analysis.

Following the trial, the jury found Castle guilty of the charged offense. Castle was sentenced in September 2025 to 15 to 20 years’ incarceration with credit for 64 days’ time previously served. He now appeals.

III. ASSIGNMENTS OF ERROR Castle assigns, restated, condensed, and reordered, that (1) the district court erred by declining his proposed jury instruction; (2) the district court erred by allowing the State, over his objections, to introduce expert testimony which bolstered L.R.’s credibility or validated her allegations; (3) the district court erred by overruling his hearsay objections without providing a limiting instruction; and (4) his defense counsel provided ineffective assistance in specific ways.

IV. ANALYSIS 1. JURY INSTRUCTION

Castle assigns that the district court erred by refusing to give his requested jury instruction regarding the definition of “sexual penetration.” For the following reasons, we reject this assigned error.

(a) Standard of Review

Whether jury instructions given by a trial court are correct is a question of law, which an appellate court resolves independently of the lower court’s decision. State v. Flores, 321 Neb. 284, 34 N.W.3d 106 (2026).

(b) Additional Facts

Following the trial but prior to the submission of the case to the jury, a jury instruction conference was held. During the conference, Castle objected to the court’s proposed instruction which verbatim stated that “‘[s]exual [p]enetration’ shall mean any intrusion, however slight, into the genital or anal openings of a victim by any part of the [d]efendant’s body which can be reasonably construed as being for non-medical, non-health, or non-law enforcement purposes.” Castle submitted a proposed instruction which would have instructed the jury regarding the definition of “sexual penetration” using the exact statutory language provided by Neb. Rev. Stat. § 28-318 (Supp. 2025). The court, however, rejected Castle’s proposed jury instruction and instructed the jury using its initial definition.

(c) Application to Castle’s Claims Here, Castle was charged with attempted first degree sexual assault of a child. Under § 28-201, a person is guilty of an attempt to commit a crime if that person intentionally engages in conduct which would constitute the crime if the attendant circumstances were as he or she believes them to be or that person intentionally engages in conduct which, under the circumstances as he or she believes them to be, constitutes a substantial step in a course of conduct intended to culminate in his or her commission of the crime. Under § 28-319.01, a person may be convicted of first degree sexual assault of a child “when he or she subjects another person under twelve years of age to sexual penetration and the actor is at least nineteen years of age or older.”

Section 28-318 provides, in relevant part, that [s]exual penetration means sexual intercourse in its ordinary meaning, cunnilingus, fellatio, anal intercourse, or any intrusion, however slight, of any part of the actor’s or victim’s body or any object manipulated by the actor into the genital or anal openings of the victim’s body which can be reasonably construed as being for nonmedical, nonhealth, or nonlaw enforcement purposes. Sexual penetration shall not require emission of semen.

Castle asserts that the court’s jury instruction was vague, confusing, and overbroad because it excluded the other examples of “sexual penetration” (sexual intercourse in its ordinary meaning, cunnilingus, fellatio, anal intercourse), as well as the sentence “[s]exual penetration shall not require emission of semen.” § 28-318. He argues that this statutory language would have made it clear to the jury that the Legislature intended for § 28-319.01 to prohibit only “sexual conduct.” Brief for appellant at 16. He also asserts that, because he was charged with an attempted crime, the statutory language would have made it obvious to the jury that it was required to find proof he intended to engage in “sexual conduct.” Id. at 17.

Castle contends the absence of this statutory language in the given instruction led the jury to incorrectly believe even nonsexual actions could sustain his conviction of the charged offense. Accordingly, he asserts that he was prejudiced by the court’s refusal to give his proposed jury instruction because there was no evidence that he had touched L.R. for “purposes of sexual arousal or gratification,” and thus there was no evidence he had engaged in “sexual conduct.” Brief for appellant at 18. Therefore, he should not have been convicted under §§ 28-319.01 and 28-201.

To establish reversible error from a court’s refusal to give a requested instruction, an appellant has the burden to show that (1) the tendered instruction is a correct statement of the law,

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