State v. Liech

320 Neb. 843
CourtNebraska Supreme Court
DecidedFebruary 20, 2026
DocketS-25-094
StatusPublished

This text of 320 Neb. 843 (State v. Liech) 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. Liech, 320 Neb. 843 (Neb. 2026).

Opinion

Nebraska Supreme Court Online Library www.nebraska.gov/apps-courts-epub/ 02/20/2026 08:07 AM CST

- 843 - Nebraska Supreme Court Advance Sheets 320 Nebraska Reports STATE V. LIECH Cite as 320 Neb. 843

State of Nebraska, appellee, v. Kim K. Liech, appellant. ___ N.W.3d ___

Filed February 20, 2026. No. S-25-094.

1. Jury Instructions. Whether jury instructions given by a trial court are correct is a question of law. 2. Convictions: Evidence: Appeal and Error. In reviewing a criminal conviction for sufficiency of the evidence, whether the evidence is direct, circumstantial, or a combination thereof, the standard is the same: An appellate court does not resolve conflicts in the evidence, pass on the credibility of witnesses, or reweigh the evidence; such matters are for the finder of fact. The relevant question is whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt. 3. Sentences: Appeal and Error. An appellate court will not disturb a sen- tence imposed within the statutory limits absent an abuse of discretion by the trial court. 4. ____: ____. An abuse of discretion takes place when the sentencing court’s reasons or rulings are clearly untenable and unfairly deprive a litigant of a substantial right and a just result. 5. Jury Instructions: Proof: Appeal and Error. To establish reversible error from a court’s refusal to give a requested instruction, an appel- lant has the burden to show that (1) the tendered instruction is a correct statement of the law, (2) the tendered instruction is warranted by the evidence, and (3) the appellant was prejudiced by the court’s refusal to give the tendered instruction. 6. Self-Defense. In Nebraska, self-defense is a statutorily defined affirma- tive defense. 7. ____. It is only unlawful force directed at a defendant which provides a justifiable basis for self-defense. - 844 - Nebraska Supreme Court Advance Sheets 320 Nebraska Reports STATE V. LIECH Cite as 320 Neb. 843

8. Trial: Evidence: Proof. The nature of an affirmative defense is such that the defendant has the initial burden of going forward with evidence of the defense. When the defendant has produced sufficient evidence to raise the defense, the issue is then one which the State must disprove. 9. Self-Defense: Jury Instructions: Evidence. If the trial evidence does not support a claim of self-defense, the jury should not be instructed on it. 10. Self-Defense. To successfully assert the claim of self-defense, a defendant must have a reasonable and good faith belief in the necessity of using force and the force used in defense must be immediately neces- sary and justified under the circumstances. 11. Self-Defense: Jury Instructions: Evidence. A trial court must instruct the jury on self-defense when there is any evidence adduced which raises a legally cognizable claim of self-defense. 12. Self-Defense: Jury Instructions. Only where the jury could reasonably find that the defendant’s use of force was justified should the trial court instruct the jury on self-defense. 13. Self-Defense: Jury Instructions: Evidence. It is only when the evi- dence does not support a legally cognizable claim of self-defense, or when the evidence is so lacking in probative value that it constitutes a failure of proof, that a trial court may properly refuse to instruct a jury on a defendant’s theory of self-defense. 14. Self-Defense: Evidence. To determine whether the evidence supports a legally cognizable claim of self-defense under Nebraska law, a trial court assesses the evidence without deciding factual issues. 15. Self-Defense: Jury Instructions. A defendant who is the initial aggres- sor is not entitled to a self-defense instruction. 16. Self-Defense. If a defendant has unjustifiably placed himself or herself in harm’s way, a court may properly find that such facts do not support a lawful claim of self-defense. 17. Criminal Law: Evidence: Appeal and Error. When a criminal defendant challenges the sufficiency of the evidence upon which a con- viction is based, the relevant question for an appellate court is whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt. 18. Criminal Law: Intent: Circumstantial Evidence. When an element of a crime involves existence of a defendant’s mental process or other state of mind of an accused, such elements may be proved by circum- stantial evidence. 19. Sentences: Appeal and Error. Where a sentence imposed within the statutory limits is alleged on appeal to be excessive, the appellate court - 845 - Nebraska Supreme Court Advance Sheets 320 Nebraska Reports STATE V. LIECH Cite as 320 Neb. 843

must determine whether a sentencing court abused its discretion in considering and applying the relevant factors, as well as any applicable legal principles in determining the sentence to be imposed. 20. ____: ____. When determining whether a sentencing court abused its discretion, it is not the proper function of an appellate court to conduct a de novo review or engage in a reweighing of the sentencing factors in the record.

Appeal from the District Court for Lancaster County: Matthew O. Mellor, Judge. Affirmed.

Kristi J. Egger, Lancaster County Public Defender, and Matthew F. Meyerle for appellant.

Michael T. Hilgers, Attorney General, Teryn Blessin and Danielle Jewell, Senior Certified Law Student, for appellee.

Funke, C.J., Cassel, Stacy, and Papik, JJ., and Heavican, Retired C.J., and Martinez, District Judge.

Stacy, J. In this appeal, an inmate challenges his felony conviction for assaulting a correctional officer. He contends that the trial court erred in refusing his proposed jury instruction on self- defense, that the evidence was insufficient to support his con- viction, and that he received an excessive sentence. We find no merit to his assigned errors and therefore affirm the conviction and sentence.

I. BACKGROUND At all relevant times, Kim K. Liech was serving a prison sentence in the custody of the Nebraska Department of Correctional Services. He was housed in unit “A” at the Reception and Treatment Center in Lancaster County. On December 20, 2022, Cpl. Johnie Cantrell was a cor- rectional officer assigned to unit “A,” and Officer Daniel Lane was a trainee shadowing Cantrell. It is undisputed that while Cantrell and Lane were working in the “pantry office” - 846 - Nebraska Supreme Court Advance Sheets 320 Nebraska Reports STATE V. LIECH Cite as 320 Neb. 843

of unit “A,” Liech entered the office and struck Cantrell twice in the head. Liech was charged with assault by a confined person, in violation of Neb. Rev. Stat. § 28-932 (Reissue 2016). He pled not guilty, and a 2-day jury trial was conducted in the district court for Lancaster County. 1. Jury Trial At trial, the State called both Cantrell and Lane to testify, and it offered video footage from prison security cameras. The defense called Liech and another inmate, Michael Brown, to testify. We summarize this evidence only as necessary to address the issues raised on appeal. (a) Security Camera Footage Video cameras mounted in the hallway of unit “A” recorded the events of December 20, 2022, from a vantage point outside the pantry office door. The footage did not capture audio, and the inside of the office area is largely outside camera range. In the video footage, Liech is carrying a laundry bag as he approaches the open office door. Liech stands in the office doorway with his feet straddling a red line on the floor near the doorway, and he appears to be arguing with someone inside the office.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Marshall
573 N.W.2d 406 (Nebraska Supreme Court, 1998)
State v. Kinser
567 N.W.2d 287 (Nebraska Supreme Court, 1997)
State v. Eagle Thunder
266 N.W.2d 755 (Nebraska Supreme Court, 1978)
State v. Urbano
589 N.W.2d 144 (Nebraska Supreme Court, 1999)
State v. Case
304 Neb. 829 (Nebraska Supreme Court, 2020)
State v. Starks
308 Neb. 527 (Nebraska Supreme Court, 2021)
State v. Haynie
476 N.W.2d 905 (Nebraska Supreme Court, 1991)
State v. Gonzalez
313 Neb. 520 (Nebraska Supreme Court, 2023)
State v. Valadez
987 N.W.2d 268 (Nebraska Supreme Court, 2023)
State v. Johnson
988 N.W.2d 159 (Nebraska Supreme Court, 2023)
State v. Alkazahy
990 N.W.2d 740 (Nebraska Supreme Court, 2023)
State v. Rieker
318 Neb. 238 (Nebraska Supreme Court, 2025)
State v. Rezac
318 Neb. 352 (Nebraska Supreme Court, 2025)
State v. Sutton
319 Neb. 581 (Nebraska Supreme Court, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
320 Neb. 843, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-liech-neb-2026.