State v. Hall

33 Neb. Ct. App. 856
CourtNebraska Court of Appeals
DecidedNovember 10, 2025
DocketA-24-980
StatusPublished
Cited by1 cases

This text of 33 Neb. Ct. App. 856 (State v. Hall) is published on Counsel Stack Legal Research, covering Nebraska Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Hall, 33 Neb. Ct. App. 856 (Neb. Ct. App. 2025).

Opinion

Nebraska Supreme Court Online Library www.nebraska.gov/apps-courts-epub/ 11/18/2025 09:14 AM CST

- 856 - Nebraska Court of Appeals Advance Sheets 33 Nebraska Appellate Reports STATE V. HALL Cite as 33 Neb. App. 856

State of Nebraska, appellee, v. Matthew A. Hall, appellant. ___ N.W.3d ___

Filed November 10, 2025. No. A-24-980.

1. Effectiveness of Counsel: Appeal and Error. Whether a claim of inef- fective assistance of trial counsel may be determined on direct appeal is a question of law. 2. ____: ____. In reviewing claims of ineffective assistance of counsel on direct appeal, an appellate court decides only whether the undisputed facts contained within the record are sufficient to conclusively deter- mine whether counsel did or did not provide effective assistance and whether the defendant was or was not prejudiced by counsel’s alleged deficient performance. 3. Effectiveness of Counsel: Postconviction: Records: Appeal and Error. When a defendant’s trial counsel is different from his or her counsel on direct appeal, the defendant must raise on direct appeal any issue of trial counsel’s ineffective performance which is known to the defendant or is apparent from the record; otherwise, the issue will be procedurally barred in a subsequent postconviction proceeding. 4. ____: ____: ____: ____. To raise an ineffective assistance of counsel claim on direct appeal, the defendant must allege deficient performance with enough particularity for (1) an appellate court to make a determina- tion of whether the claim can be decided upon the trial record and (2) a district court later reviewing a petition for postconviction relief to recognize whether the claim was brought before the appellate court. 5. Effectiveness of Counsel: Proof: Appeal and Error. When a claim of ineffective assistance of counsel is raised in a direct appeal, the appel- lant is not required to allege prejudice; however, an appellant must make specific allegations of the conduct that he or she claims constitutes defi- cient performance by trial counsel. 6. Effectiveness of Counsel: Records: Appeal and Error. Once raised, an appellate court will determine whether the record on appeal is sufficient - 857 - Nebraska Court of Appeals Advance Sheets 33 Nebraska Appellate Reports STATE V. HALL Cite as 33 Neb. App. 856

to review the merits of the ineffective performance claims. The record is sufficient if it establishes either that trial counsel’s performance was not deficient, that the appellant will not be able to establish prejudice as a matter of law, or that trial counsel’s actions could not be justified as a part of any plausible trial strategy. 7. Effectiveness of Counsel: Proof. To prevail on a claim of ineffective assistance of counsel under Strickland v. Washington, 466 U.S. 668, 104 S. Ct. 2052, 80 L. Ed. 2d 674 (1984), the defendant must show that his or her counsel’s performance was deficient and that this deficient performance actually prejudiced the defendant’s defense. 8. ____: ____. To show that counsel’s performance was deficient, the defendant must show counsel’s performance did not equal that of a lawyer with ordinary training and skill in criminal law. To show preju- dice under the prejudice component of Strickland v. Washington, 466 U.S. 668, 104 S. Ct. 2052, 80 L. Ed. 2d 674 (1984), the defendant must demonstrate a reasonable probability that but for his or her coun- sel’s deficient performance, the result of the proceeding would have been different. 9. Effectiveness of Counsel: Appeal and Error. Assignments of error on direct appeal regarding ineffective assistance of trial counsel must specifically allege deficient performance, and an appellate court will not scour the remainder of the brief in search of such specificity. 10. ____: ____. A general assignment of ineffective assistance that does not specify counsel’s deficiency is insufficient to raise the claim on direct appeal. 11. Effectiveness of Counsel: Witnesses: Appeal and Error. To effectively raise on direct appeal a claim of ineffective assistance of trial counsel in relation to the failure to call witnesses, appellate counsel must give on direct appeal the names or descriptions of any uncalled witnesses form- ing the basis of a claim of ineffective assistance of trial counsel. 12. ____: ____: ____. Vague assertions that counsel was deficient for fail- ing to call “witnesses” are little more than placeholders and do not suf- ficiently preserve the claim. 13. ____: ____: ____. References to trial counsel’s failure to call “character witnesses,” “multiple eyewitnesses,” and “alibi witnesses” have been deemed insufficiently specific to effectively raise a claim of ineffective assistance of counsel on direct appeal. 14. Lesser-Included Offenses: Jury Instructions: Evidence. A court must instruct on a lesser-included offense if (1) the elements of the lesser offense for which an instruction is requested are such that one cannot commit the greater offense without simultaneously committing the lesser offense and (2) the evidence produces a rational basis for acquitting the - 858 - Nebraska Court of Appeals Advance Sheets 33 Nebraska Appellate Reports STATE V. HALL Cite as 33 Neb. App. 856

defendant of the greater offense and convicting the defendant of the lesser offense. 15. ____: ____: ____. It is not prejudicial error to fail to instruct upon a lesser-included offense when the evidence entirely fails to show an offense of a lesser degree than that charged in the information. 16. Criminal Attempt: Lesser-Included Offenses. To be guilty of an attempt, a person must intentionally engage in conduct constituting a substantial step toward the completion of the underlying crime. 17. Effectiveness of Counsel: Jury Instructions: Appeal and Error. To effectively raise on direct appeal a claim of ineffective assistance of trial counsel for failing to file and offer other appropriate jury instructions or failing to object to the jury instructions as given, appellate counsel must give on direct appeal the specific subject or description of any jury instruction that forms the basis of a claim of ineffective assistance of trial counsel. 18. Criminal Law: Directed Verdict. In a criminal case, the court can direct a verdict only when (1) there is a complete failure of evidence to establish an essential element of the crime charged or (2) evidence is so doubtful in character and lacking in probative value that a finding of guilt based on such evidence cannot be sustained. 19. Criminal Law: Directed Verdict: Appeal and Error. In an appellate court’s consideration of a criminal defendant’s motion for a directed verdict, the State is entitled to have all its relevant evidence accepted as true, every controverted fact resolved in its favor, and every beneficial inference reasonably deducible from the evidence. 20. Directed Verdict. If there is any evidence which will sustain a find- ing for the party against whom a motion for directed verdict is made, the case may not be decided as a matter of law, and a verdict may not be directed. 21. Appeal and Error. Only the issues that have been specifically assigned and specifically argued on appeal will be considered by an appellate court.

Appeal from the District Court for Scotts Bluff County: Leo P. Dobrovolny, Judge. Affirmed. Sterling T. Huff, P.C., L.L.O., for appellant. Michael T. Hilgers, Attorney General, and Teryn Blessin for appellee. Pirtle, Bishop, and Freeman, Judges. - 859 - Nebraska Court of Appeals Advance Sheets 33 Nebraska Appellate Reports STATE V. HALL Cite as 33 Neb. App. 856

Freeman, Judge. INTRODUCTION Matthew A. Hall appeals from his convictions and sentences following a jury trial in Scotts Bluff County District Court. He claims that his trial counsel was ineffective in various respects. For the reasons set forth below, we affirm.

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Bluebook (online)
33 Neb. Ct. App. 856, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-hall-nebctapp-2025.