State v. Hearnes

34 Neb. Ct. App. 182
CourtNebraska Court of Appeals
DecidedMarch 31, 2026
DocketA-24-753
StatusPublished

This text of 34 Neb. Ct. App. 182 (State v. Hearnes) 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. Hearnes, 34 Neb. Ct. App. 182 (Neb. Ct. App. 2026).

Opinion

Nebraska Supreme Court Online Library www.nebraska.gov/apps-courts-epub/ 03/31/2026 08:08 AM CDT

- 182 - Nebraska Court of Appeals Advance Sheets 34 Nebraska Appellate Reports STATE v. HEARNES Cite as 34 Neb. App. 182

State of Nebraska, appellee, v. Robert L. Hearnes, Sr., appellant. ___ N.W.3d ___

Filed March 31, 2026. No. A-24-753.

1. Trial: Joinder: Appeal and Error. A trial court’s ruling on a motion for consolidation of prosecutions properly joinable will not be disturbed on appeal absent an abuse of discretion. 2. Rules of Evidence: Appeal and Error. Where the Nebraska Evidence Rules commit the evidentiary question at issue to the discretion of the trial court, an appellate court reviews the admissibility of evidence for an abuse of discretion. 3. Hearsay: Appeal and Error. Apart from rulings under the residual hearsay exception, an appellate court reviews for clear error the factual findings underpinning a trial court’s hearsay ruling and reviews de novo the court’s ultimate determination to admit evidence over a hearsay objection or exclude evidence on hearsay grounds. 4. Hearsay. Whether a statement was both taken and given in contempla- tion of medical diagnosis or treatment is a factual finding made by the trial court in determining the admissibility of the evidence. 5. 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. 6. ____: ____. 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. 7. Criminal Law: Trial: Joinder. Joinder of multiple offenses for a single trial is favored and is the rule rather than the exception in crimi- nal cases. - 183 - Nebraska Court of Appeals Advance Sheets 34 Nebraska Appellate Reports STATE v. HEARNES Cite as 34 Neb. App. 182

8. Trial: Joinder: Appeal and Error. Whether offenses were properly joined involves a two-stage analysis: (1) whether the offenses were suf- ficiently related so as to be joinable and (2) whether the joinder was prejudicial to the defendant. 9. Criminal Law: Joinder: Presumptions. A clear presumption exists in favor of a joinder of offenses and against severance. 10. Trial: Joinder: Proof. A defendant opposing joinder of charges must meet a high burden of proving prejudice. To carry that burden, the defendant must show compelling, specific, and actual prejudice. 11. Evidence: Other Acts: Time. The question whether evidence of other conduct is too remote in time is largely within the discretion of the trial court. While remoteness in time may weaken the value of the evidence, such remoteness does not, in and of itself, necessarily justify exclusion of the evidence. 12. Evidence: Hearsay: Proof. Statements having a dual medical and investigatory purpose are admissible only if the proponent of the state- ments demonstrates that (1) the declarant’s purpose in making the statements was to assist in the provision of medical diagnosis or treat- ment and (2) the statements were of a nature reasonably pertinent to medical diagnosis or treatment by a medical professional. 13. Evidence: Intent. There need not be direct evidence of a declarant’s state of mind; instead, the appropriate state of mind of the declarant may be reasonably inferred from the circumstances. 14. Intent. Whether the circumstances warrant inferring an appropriate state of mind is necessarily a fact-specific determination. 15. Indictments and Informations. An information must inform the accused with reasonable certainty of the crime charged so that the accused may prepare a defense to the prosecution and, if convicted, be able to plead the judgment of conviction on such charge as a bar to a later prosecution for the same offense. 16. ____. A trial court, in its discretion, may permit a criminal information to be amended at any time before verdict or findings if no additional or different offense is charged and the substantial rights of the defendant are not prejudiced. 17. Appeal and Error. An assignment of error is specific when it addresses a specific issue that does not require additional information to under- stand precisely what the assignment attacks. 18. Effectiveness of Counsel: Appeal and Error. To preserve an inef- fective assistance of counsel claim on direct appeal, the claim must be stated with particularity in the assignment of error and then sepa- rately argued. - 184 - Nebraska Court of Appeals Advance Sheets 34 Nebraska Appellate Reports STATE v. HEARNES Cite as 34 Neb. App. 182

19. Effectiveness of Counsel: Postconviction: Records: Appeal and Error. An ineffective assistance of counsel claim is raised on direct appeal when the claim alleges deficient performance with enough par- ticularity for (1) an appellate court to make a determination 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. 20. Effectiveness of Counsel: Proof. To prevail on a claim of ineffective assistance of counsel, the defendant must show that his or her counsel’s performance was deficient and that this deficient performance preju- diced the defendant’s defense. 21. ____: ____. To show that counsel’s performance was deficient, a defendant must show that counsel’s performance did not equal that of a lawyer with ordinary training and skill in criminal law. 22. ____: ____. To show prejudice in a claim of ineffective assistance of counsel, the defendant must demonstrate a reasonable probability that but for counsel’s deficient performance, the result of the proceeding would have been different. 23. Effectiveness of Counsel: Words and Phrases. A reasonable probabil- ity of prejudice from ineffective assistance of counsel is a probability sufficient to undermine confidence in the outcome. 24. Effectiveness of Counsel. Speculation alone does not support a claim for ineffective assistance of counsel.

Appeal from the District Court for Douglas County: Kimberly Miller Pankonin, Judge. Affirmed. Jerry M. Hug, of Hug & Jacobs, L.L.C., for appellant. Michael T. Hilgers, Attorney General, and Melissa R. Vincent for appellee. Welch and Freeman, Judges. Freeman, Judge. INTRODUCTION Following a jury trial, Robert L. Hearnes, Sr., appeals his convictions for sexual assault of a child in the first and third degree involving two minor children, J.W. and H.C., entered by the district court for Douglas County. He argues that the district court erred in consolidating his charges, admitting - 185 - Nebraska Court of Appeals Advance Sheets 34 Nebraska Appellate Reports STATE v. HEARNES Cite as 34 Neb. App. 182

evidence of a prior sexual assault, admitting hearsay evi- dence, and granting an amendment to the information. He also argues that his trial counsel was ineffective. For the reasons explained below, we affirm. BACKGROUND The district court heard several motions throughout the pendency of the case as discussed below. Motion to Consolidate. Prior to trial, the State moved to consolidate the charges as to both children into one matter. Hearnes argued that the con- solidation was prejudicial because it made it appear that there was a common scheme or plan. In its motion, the State asserted both matters involved the sexual assault of a female child under or around the age of 12, both involved penile-vaginal penetration, and both involved Hearnes’ approaching the child while the child was alone, although others may have been elsewhere in the respective residences.

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Bluebook (online)
34 Neb. Ct. App. 182, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-hearnes-nebctapp-2026.