State v. Mielak

CourtNebraska Supreme Court
DecidedJune 12, 2026
DocketS-24-064
StatusPublished

This text of State v. Mielak (State v. Mielak) 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. Mielak, (Neb. 2026).

Opinion

Nebraska Supreme Court Online Library www.nebraska.gov/apps-courts-epub/ 06/12/2026 08:10 AM CDT

- 542 - Nebraska Supreme Court Advance Sheets 321 Nebraska Reports STATE v. MIELAK Cite as 321 Neb. 542

State of Nebraska, appellee, v. Evan J. Mielak, appellant. ___ N.W.3d ___

Filed June 12, 2026. No. S-24-064.

1. Convictions: Evidence: Appeal and Error. In reviewing a criminal conviction for sufficiency of the evidence to sustain the conviction, the relevant question for an appellate court is whether, after viewing the evi- dence 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. 2. Statutes: Appeal and Error. Statutory interpretation is a question of law that an appellate court resolves independently of the trial court. 3. Jury Instructions: Appeal and Error. Whether jury instructions given by a trial court are correct is a question of law. On a question of law, an appellate court is obligated to reach a conclusion independent of the determination reached by the court below. 4. Statutes: Words and Phrases. When terms in a statute are not spe- cifically defined by the Legislature, principles of statutory interpreta- tion generally require courts to give such terms their plain and ordi- nary meaning. 5. Criminal Law: Legislature: Words and Phrases. When the Legislature has defined specific terms for the purpose of the Nebraska Criminal Code, courts will apply such definitions unless the context requires otherwise. 6. Statutes: Legislature: Intent. In construing a statute, a court must determine and give effect to the purpose and intent of the Legislature as ascertained from the entire language of the statute considered in its plain, ordinary, and popular sense. 7. Statutes. It is not within the province of the courts to read a meaning into a statute that is not there or to read anything direct and plain out of a statute. - 543 - Nebraska Supreme Court Advance Sheets 321 Nebraska Reports STATE v. MIELAK Cite as 321 Neb. 542

8. Sexual Assault. For purposes of expressing a lack of consent through conduct under Neb. Rev. Stat. § 28-318(8)(a)(iii) (Cum. Supp. 2024), a victim’s conduct can include both actions and omissions and can include a series of acts and omissions. 9. Jury Instructions: Proof: Appeal and Error. To establish reversible error from a court’s refusal to give a requested jury instruction, an appellant has the burden to show that (1) the tendered instruction is a correct statement of the law, (2) the tendered instruction was warranted by the evidence, and (3) the appellant was prejudiced by the court’s failure to give the requested instruction. 10. Jury Instructions: Records: Appeal and Error. It is incumbent upon an appellant to supply a record which supports his or her appeal, and when a proposed instruction is not included in the record on appeal, the appellate court has no instruction to review in order to determine whether it ought to have been given.

Petition for further review from the Court of Appeals, Pirtle, Bishop, and Arterburn, Judges, on appeal thereto from the District Court for Lancaster County, Kevin R. McManaman, Judge. Judgment of Court of Appeals affirmed.

Robert B. Creager, of Anderson, Creager & Wittstruck, P.C., L.L.O., for appellant.

Michael T. Hilgers, Attorney General, and Jordan Osborne for appellee.

Miller-Lerman, Cassel, Stacy, Papik, Freudenberg, and Bergevin, JJ.

Stacy, J. After a jury trial, Evan J. Mielak was convicted of first degree sexual assault for digitally penetrating his roommate while she was intoxicated and appeared to be asleep or uncon- scious. The Nebraska Court of Appeals affirmed his convic- tion. 1 Mielak seeks further review, challenging the sufficiency of the evidence to support his conviction and arguing that it 1 State v. Mielak, 33 Neb. App. 309, 16 N.W.3d 143 (2025). - 544 - Nebraska Supreme Court Advance Sheets 321 Nebraska Reports STATE v. MIELAK Cite as 321 Neb. 542

was error to refuse his proposed jury instruction. We granted further review to address two issues: (1) what type of con- duct is required to express a lack of consent for purposes of Neb. Rev. Stat. § 28-318(8)(a)(iii) (Cum. Supp. 2024) and (2) whether an intoxicated victim can be “mentally or physically incapable of resisting or appraising” the nature of the conduct under Neb. Rev. Stat. § 28-319(1)(b) (Reissue 2016) if the vic- tim was aware of the penetration as it was occurring. Although our reasoning differs somewhat from that articulated by the Court of Appeals, we affirm its decision.

I. BACKGROUND On June 7, 2023, Mielak was charged in the district court for Lancaster County with the first degree sexual assault of H.S. in violation of § 28-319(1). The information alleged that on or about April 7, 2023, Mielak subjected H.S. to sexual penetration either without consent or when Mielak knew or should have known that H.S. was mentally or physically incapable of resisting or appraising the nature of his conduct. Mielak pled not guilty, and the matter proceeded to trial. Over the course of a 3-day jury trial, the State called mul- tiple witnesses, including H.S. and four of her roommates. Mielak did not testify and did not call any witnesses. To address the issues raised on further review, we summarize the trial evidence viewed in the light most favorable to the State. 2

1. Trial Evidence In April 2023, H.S. shared an apartment with her sister and four male roommates, including Mielak. H.S. and her sister shared a bedroom, and they also shared exclusive use of the bathroom nearest their bedroom; the roommates agreed that males were not allowed in that bathroom. 2 See State v. Vazquez, 319 Neb. 192, 21 N.W.3d 615 (2025) (when reviewing criminal conviction for sufficiency of evidence, appellate court views evidence in light most favorable to prosecution). - 545 - Nebraska Supreme Court Advance Sheets 321 Nebraska Reports STATE v. MIELAK Cite as 321 Neb. 542

On April 7, 2023, a group of roommates, including H.S., her sister, and Mielak, were playing a drinking game in the apartment. The players consumed large amounts of alcohol in a short period of time. After consuming about five alcoholic seltzer drinks in 1 hour, H.S. was intoxicated and began to feel unwell. She left the group and went to her bathroom to vomit. After vomiting, H.S. still felt unwell, so she stayed in the bath- room with the door closed. Eventually, H.S. fell asleep next to the toilet, lying face down on the bathroom floor. Several of the roommates realized H.S. was “pretty drunk,” and they encouraged her sister to check on her. The sister went to the bathroom and offered H.S. some water. H.S. mumbled something but did not move or reach for the water, so the sis- ter set the water next to H.S. and left the bathroom. After clos- ing the bathroom door, the sister encountered Mielak standing just outside the bathroom door. Mielak offered to help take care of H.S., but the sister told Mielak that she would take care of things, and she reminded Mielak he was not allowed in that bathroom. The sister then walked to the opposite end of the apartment to take a phone call. H.S. testified that she remembered only parts of what hap- pened after she went into the bathroom. She recalled getting sick, her sister coming in to check on her and bringing her water, and falling asleep next to the toilet while lying on her stomach. H.S. also recalled waking up and realizing that another person was in the bathroom with her. H.S.

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Bluebook (online)
State v. Mielak, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-mielak-neb-2026.