State v. Logan

320 Neb. 554
CourtNebraska Supreme Court
DecidedDecember 19, 2025
DocketS-24-813
StatusPublished

This text of 320 Neb. 554 (State v. Logan) 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. Logan, 320 Neb. 554 (Neb. 2025).

Opinion

Nebraska Supreme Court Online Library www.nebraska.gov/apps-courts-epub/ 12/19/2025 08:07 AM CST

- 554 - Nebraska Supreme Court Advance Sheets 320 Nebraska Reports STATE V. LOGAN Cite as 320 Neb. 554

State of Nebraska, appellee, v. Elijah E. Logan, appellant. ___ N.W.3d ___

Filed December 19, 2025. No. S-24-813.

1. Rules of Evidence: Other Acts. An appellate court will review for abuse of discretion a trial court’s evidentiary rulings on the admissibility of a defendant’s other crimes or bad acts under Neb. Evid. R. 404(2), Neb. Rev. Stat. § 27-404(2) (Cum. Supp. 2024), or under the inextrica- bly intertwined exception to the rule. 2. Judgments: Words and Phrases. An abuse of discretion occurs when a trial court’s decision is based upon reasons that are untenable or unrea- sonable or if its action is clearly against justice or conscience, reason, and evidence. 3. Jury Instructions: Appeal and Error. Whether jury instructions are correct is a question of law, which an appellate court resolves indepen- dently of the lower court’s decision. 4. Trial: Witnesses. The exclusion or sequestration of a witness is within the discretion of the trial court. 5. Double Jeopardy: Convictions: Appeal and Error. Whether two con- victions result in multiple punishments for the same offense for double jeopardy purposes presents a question of law, on which an appellate court reaches a conclusion independent of the court below. 6. Appeal and Error. Consideration of plain error occurs at the discretion of an appellate court. 7. Rules of Evidence: Other Acts. Under Neb. Evid. R. 404(2), Neb. Rev. Stat. § 27-404(2) (Cum. Supp. 2024), evidence of other crimes, wrongs, or acts is not admissible to prove the character of a person in order to show that he or she acted in conformity therewith. 8. ____: ____. Neb. Evid. R. 404(2), Neb. Rev. Stat. § 27-404(2) (Cum. Supp. 2024), does not apply to evidence of a defendant’s other crimes or bad acts if the evidence is inextricably intertwined with the charged crime. - 555 - Nebraska Supreme Court Advance Sheets 320 Nebraska Reports STATE V. LOGAN Cite as 320 Neb. 554

9. ____: ____. Inextricably intertwined evidence includes evidence that forms part of the factual setting of the crime and evidence that is so blended or connected to the charged crime that proof of the charged crime will necessarily require proof of the other crimes or bad acts. Evidence of other crimes or bad acts is also inextricably intertwined with the charged crime if the other crimes or bad acts are necessary for the prosecution to present a coherent picture of the charged crime. 10. Jury Instructions: Appeal and Error. The failure to provide a limiting instruction absent a request is not reversible error. 11. Criminal Law: Trial: Evidence: Appeal and Error. An error in admit- ting or excluding evidence in a criminal trial, whether of constitutional magnitude or otherwise, is prejudicial unless it can be said that the error was harmless beyond a reasonable doubt. 12. Verdicts: Juries: Appeal and Error. Harmless error review looks to the basis on which the trier of fact actually rested its verdict; the inquiry is not whether in a trial that occurred without the error a guilty verdict would surely have been rendered, but, rather, whether the actual guilty verdict rendered in the questioned trial was surely unattributable to the error. 13. 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. 14. Self-Defense: Evidence: Proof. Justifications for the use of force in self-defense are statutorily defined, and the defendant bears the initial burden to produce evidence which supports a claim of self-defense. 15. Self-Defense: Jury Instructions. A trial court is required to give a self-defense instruction where there is any evidence in support of a legally cognizable theory of self-defense. 16. ____: ____. Only where the jury could reasonably find that the defen- dant’s use of force was justified should the trial court instruct the jury on self-defense. 17. Self-Defense: Jury Instructions: Evidence. To instruct on self-defense, it is not enough that the defendant subjectively believed in the need to use force for self-protection; the defendant must produce evidence that this subjective belief was also objectively reasonable. 18. 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. - 556 - Nebraska Supreme Court Advance Sheets 320 Nebraska Reports STATE V. LOGAN Cite as 320 Neb. 554

19. Trial: Witnesses: Testimony. Generally speaking, a request for seques- tration of witnesses is a request that they be excluded from the court- room until called to testify. 20. Trial: Witnesses. Sequestration is based on the belief that not hearing other witnesses’ testimony tends to better elicit the truth and promote the ends of justice. 21. Trial: Witnesses: Rules of Evidence. For purposes of Neb. Evid. R. 615(3), Neb. Rev. Stat. § 27-615(3) (Reissue 2016), a victim in a crimi- nal case may be qualified as an essential person. 22. Trial: Witnesses: Appeal and Error. The denial of a sequestration motion will not be overturned absent evidence of prejudice to the defendant. 23. Double Jeopardy. The respective Double Jeopardy Clauses of the U.S. and Nebraska Constitutions protect against three distinct abuses: (1) a second prosecution for the same offense after acquittal, (2) a second prosecution for the same offense after conviction, and (3) multiple pun- ishments for the same offense. 24. Homicide: Double Jeopardy. Where a defendant is alternately charged with both premeditated murder and felony murder and the record is not clear under which theory the jury found the defendant guilty, then the defendant cannot be sentenced for both the murder and the predicate felony for felony murder. 25. Sentences: Weapons. Neb. Rev. Stat. § 28-1205 (Reissue 2016) man- dates that a sentence for the use of a deadly weapon in the commission of a felony be served consecutively to any other sentence imposed and concurrent with no other sentence.

Appeal from the District Court for Washington County: Bryan C. Meismer, Judge. Convictions affirmed, all sentences vacated, and cause remanded for resentencing.

Robert W. Kortus, of Nebraska Commission on Public Advocacy, for appellant.

Michael T. Hilgers, Attorney General, and Austin N. Relph for appellee.

Funke, C.J., Cassel, Stacy, Papik, Freudenberg, and Bergevin, JJ., and Riedmann, Chief Judge. - 557 - Nebraska Supreme Court Advance Sheets 320 Nebraska Reports STATE V. LOGAN Cite as 320 Neb. 554

Cassel, J. INTRODUCTION In this direct appeal, Elijah E. Logan challenges the district court’s admitting evidence of his prior uncharged assaults against S.E. under the inextricably intertwined doctrine, refus- ing to instruct the jury on self-defense, and not sequestering S.E. Finding no error in those respects, we affirm his con- victions. Logan also asserts error with respect to sentencing.

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Bluebook (online)
320 Neb. 554, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-logan-neb-2025.