State v. Falcon

319 Neb. 911
CourtNebraska Supreme Court
DecidedSeptember 19, 2025
DocketS-23-953
StatusPublished
Cited by2 cases

This text of 319 Neb. 911 (State v. Falcon) is published on Counsel Stack Legal Research, covering Nebraska Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Falcon, 319 Neb. 911 (Neb. 2025).

Opinion

Nebraska Supreme Court Online Library www.nebraska.gov/apps-courts-epub/ 09/19/2025 09:09 AM CDT

- 911 - Nebraska Supreme Court Advance Sheets 319 Nebraska Reports STATE V. FALCON Cite as 319 Neb. 911

State of Nebraska, appellee, v. Shaquille M. Falcon, appellant. ___ N.W.3d ___

Filed September 19, 2025. No. S-23-953.

1. Constitutional Law: Search and Seizure: Motions to Suppress: Appeal and Error. When reviewing a trial court’s ruling on a motion to suppress based on a claimed violation of the Fourth Amendment, an appellate court applies a two-part standard of review. Regarding histori- cal facts, an appellate court reviews the trial court’s findings for clear error, but whether those facts trigger or violate Fourth Amendment protections is a question of law that an appellate court reviews indepen- dently of the trial court’s determination. 2. Trial: Evidence: Appeal and Error. An appellate court reviews the trial court’s ruling on authentication for abuse of discretion. 3. Constitutional Law: Witnesses: Appeal and Error. An appellate court reviews de novo a trial court’s determination of the protections afforded by the Confrontation Clause and reviews the underlying factual determi- nations for clear error. 4. Constitutional Law: Search and Seizure. All evidence obtained by searches and seizures in violation of the federal Constitution is inadmis- sible in a criminal trial in a state court. 5. ____: ____. Under the Fourth Amendment, a search with consent is a reasonable search. 6. Warrantless Searches: Search and Seizure: Proof. The State has the burden of showing the applicability of one or more of the exceptions to the warrant requirement. 7. Search and Seizure: Motor Vehicles. The driver of a vehicle is the person who has immediate possession of and control over the vehicle and has the authority to consent to a search of that vehicle. 8. Constitutional Law: Search and Seizure. The touchstone of the Fourth Amendment is reasonableness, and the reasonableness of a - 912 - Nebraska Supreme Court Advance Sheets 319 Nebraska Reports STATE V. FALCON Cite as 319 Neb. 911

search is determined by assessing, on the one hand, the degree to which it intrudes upon an individual’s privacy and, on the other, the degree to which it is needed for the promotion of legitimate govern- mental interests. 9. Constitutional Law: Police Officers and Sheriffs: Search and Seizure. Law enforcement officers are often required to perform non- criminal community caretaking functions, which are totally divorced from the detection, investigation, or acquisition of evidence relating to the violation of a criminal statute. Such community caretaking func- tions are a legitimate governmental interest. 10. ____: ____: ____. Community caretaking functions are not subject to a special Fourth Amendment doctrine or rule—the basic Fourth Amendment question of reasonableness applies. 11. Police Officers and Sheriffs: Evidence. Police practices trigger the harsh sanction of exclusion only when they are deliberate enough to yield meaningful deterrence and culpable enough to be worth the price paid by the justice system. 12. Rules of Evidence: Hearsay. A declarant is the key for purposes of Neb. Rev. Stat. § 27-803(6) (Cum. Supp. 2024)—an out-of-court state- ment needs to be made as part of the declarant’s business. 13. ____: ____. For self-authentication under Neb. Rev. Stat. § 27-902(11) (Cum. Supp. 2024) to apply in a criminal case, such that extrinsic evi- dence of authenticity is not a required condition precedent to admissibil- ity, the domestic record sought to be introduced must meet the require- ments of Neb. Rev. Stat. § 27-803(6)(a) (Cum. Supp. 2024). 14. Constitutional Law: Witnesses. The Confrontation Clause guarantees a defendant’s right to confront witnesses who bear testimony against him or her.

Petition for further review from the Court of Appeals, Pirtle, Bishop, and Arterburn, Judges, on appeal thereto from the District Court for Lancaster County, Susan I. Strong, Judge. Judgment of Court of Appeals affirmed. Robert Wm. Chapin, Jr., for appellant. Michael T. Hilgers, Attorney General, and Teryn Blessin for appellee. Funke, C.J., Miller-Lerman, Cassel, Stacy, Papik, Freudenberg, and Bergevin, JJ. - 913 - Nebraska Supreme Court Advance Sheets 319 Nebraska Reports STATE V. FALCON Cite as 319 Neb. 911

Bergevin, J. I. INTRODUCTION The Nebraska Court of Appeals affirmed Shaquille M. Falcon’s convictions on direct appeal. 1 Falcon petitioned for further review and assigned that the Court of Appeals erred in its resolution of each of his four assignments of error. 2 We granted further review primarily to address the Court of Appeals’ analysis of Falcon’s motion to suppress and its interpretation and application of Neb. Rev. Stat. § 27-902(11) (Cum. Supp. 2024), which provides for the self-authentication of domestic records that meet the requirements of Neb. Rev. Stat. § 27-803(6) (Cum. Supp. 2024). We agree with the Court of Appeals’ conclusions and resolu- tion of Falcon’s appeal, and we affirm. However, our reasoning contains minor differences from that of the Court of Appeals, which we highlight below. II. BACKGROUND Falcon was convicted of possession of a firearm by a pro- hibited person, a Class ID felony, 3 and driving under the influ- ence (DUI), first offense, a Class W misdemeanor. 4 The parties stipulated that Falcon had a prior felony conviction, and it was undisputed that he was a prohibited person. The main issue at the jury trial was whether Falcon knowingly possessed the firearm. The theory of Falcon’s defense was that unbeknownst to him, the firearm was present in the vehicle when he borrowed it. To prove Falcon knowingly possessed the firearm, the State primarily relied on two pieces of evidence: the firearm that was discovered in the vehicle and Facebook messages that were purportedly sent by Falcon. The State contended that the 1 See State v. Falcon, 33 Neb. App. 331, 16 N.W.3d 393 (2025). 2 See, generally, Neb. Ct. R. App. P. § 2-102(F) to (H) (rev. 2022). 3 See Neb. Rev. Stat. § 28-1206 (Cum. Supp. 2022). 4 See Neb. Rev. Stat. §§ 60-6,196 and 60-6,197.03(2) (Reissue 2021). - 914 - Nebraska Supreme Court Advance Sheets 319 Nebraska Reports STATE V. FALCON Cite as 319 Neb. 911

Facebook messages associated the firearm with Falcon, not the vehicle. Falcon challenged the admissibility of evidence related to the firearm and the Facebook messages, which are the two main subjects of our further review. The factual background of this case is set forth in detail within the Court of Appeals’ opinion. 5 Accordingly, we sup- ply additional background information below relevant to our analyses of the issues before us. III.

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Cite This Page — Counsel Stack

Bluebook (online)
319 Neb. 911, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-falcon-neb-2025.