State v. Putnam

CourtNebraska Court of Appeals
DecidedFebruary 11, 2025
DocketA-24-361
StatusUnpublished

This text of State v. Putnam (State v. Putnam) 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. Putnam, (Neb. Ct. App. 2025).

Opinion

IN THE NEBRASKA COURT OF APPEALS

MEMORANDUM OPINION AND JUDGMENT ON APPEAL (Memorandum Web Opinion)

STATE V. PUTNAM

NOTICE: THIS OPINION IS NOT DESIGNATED FOR PERMANENT PUBLICATION AND MAY NOT BE CITED EXCEPT AS PROVIDED BY NEB. CT. R. APP. P. § 2-102(E).

STATE OF NEBRASKA, APPELLEE, V.

RUSTY D. PUTNAM, APPELLANT.

Filed February 11, 2025. No. A-24-361.

Appeal from the District Court for Lancaster County: DARLA S. IDEUS, Judge. Affirmed. Christopher L. Eickholt, of Eickholt Law L.L.C., for appellant. Michael T. Hilgers, Attorney General, and Erin E. Tangeman for appellee.

RIEDMANN, Chief Judge, and PIRTLE and ARTERBURN, Judges. PIRTLE, Judge. INTRODUCTION Rusty D. Putnam appeals his conviction and sentence for second degree arson in the district court for Lancaster County. He contends that his trial counsel was ineffective and that his sentence is excessive. Based on the reasons that follow, we affirm. BACKGROUND On November 15, 2023, Putnam was charged by information with second degree arson, a Class III felony. Putnam pled not guilty, and the matter proceeded to a jury trial. At trial, Lancaster County Sheriff Deputy Dillon Hicks testified that on September 25, 2022, at approximately 4:12 a.m., he was dispatched to a suspected arson in the parking lot of Track Side Bar and Grill in Waverly, Nebraska. When he arrived on scene, Waverly Fire and Rescue had already arrived and were extinguishing a fire that was burning in a blue Dodge pickup

-1- and its attached camper trailer. After the fire was extinguished, Hicks spoke with the reporting party and took pictures of the scene. Justin Davis, a fire investigator with the Nebraska State Fire Marshall’s Office, arrived on scene after the fire was extinguished. After observing the pickup and trailer, Davis suspected that an accelerant was used in the fire. Following further investigation, including watching a video of the fire burning, Davis believed the accelerant was the application and ignition of an ignitable liquid. He agreed that the video was consistent with a fire started by gasoline. Deputies obtained videos from multiple businesses in the vicinity of the fire, including Track Side Bar and Grill, G-Force Car Wash, and Mammoth Gas Station. The video evidence from the gas station showed a silver F-150 pickup with multiple occupants enter the parking lot and pull up to a gas pump. The driver of the pickup, who was later identified as Putnam, got a bucket from the back of the truck and filled it with gasoline. The gasoline purchase was confirmed to have been made by Putnam. The pickup left the gas station and drove toward the Track Side Bar and Grill parking lot. The video evidence from Track Side Bar and Grill showed three individuals approaching the blue Dodge pickup and trailer, with one of them carrying a bucket. The individual holding the bucket tossed the fuel onto the pickup and trailer. A fire ignited and the three people ran back toward the direction from which they came. Other video evidence showed the silver F-150 pickup leave the nearby car wash parking lot and stop and idle at an intersection. Hicks noted that the driver of the silver F-150 pickup never put the vehicle into park; the brake lights remained illuminated the entire time. Video evidence also showed three individuals running toward the silver F-150 pickup, one of the individuals threw the bucket into the back of the pickup, and all three got into the pickup. Kelli Kyle was the owner of the blue Dodge pickup and the attached camper trailer. She had been living in the trailer and all her possessions were inside the trailer at the time of the fire. Kyle testified that she would park her pickup and trailer in various locations, including Track Side Bar and Grill’s parking lot, for a day or two before moving it again. Kyle was not in the camper the night of the fire because she had driven her friend Christopher Headland to Council Bluffs in her other vehicle and was gone overnight. When Kyle returned the next morning to Track Side Bar and Grill’s parking lot, her pickup and camper were gone. She later learned about the fire from law enforcement. Kyle did not know Putnam, but after the fire she learned that he was an uncle or family friend of Headland’s new girlfriend. Putnam did not testify on his own behalf at trial, nor did he present any evidence. The jury found Putnam guilty of second degree arson. The district court sentenced Putnam to 2 years’ imprisonment followed by 12 months’ post-release supervision. ASSIGNMENTS OF ERROR Putnam assigns that he received ineffective assistance of counsel because his trial counsel: (1) failed to advocate for or negotiate a plea agreement, and (2) advised him to waive his right to testify at trial. Putnam also assigns that his sentence is excessive and constitutes an abuse of discretion.

-2- STANDARD OF REVIEW Whether a claim of ineffective assistance of counsel may be determined on direct appeal is a question of law. State v. Clark, 315 Neb. 736, 1 N.W.3d 487 (2024). 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 determine whether counsel did or did not provide effective assistance and whether the defendant was or was not prejudiced by counsel’s alleged deficient performance. Id. An appellate court will not disturb a sentence imposed within the statutory limits absent an abuse of discretion by the trial court. State v. Tvrdy, 315 Neb. 756, 1 N.W.3d 479 (2024). An abuse of discretion occurs when a trial court’s decision is based upon reasons that are untenable or unreasonable or if its action is clearly against justice or conscience, reason, and evidence. Id. Where a sentence imposed within the statutory limits is alleged on appeal to be excessive, the appellate court 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. Id. ANALYSIS Ineffective Assistance of Counsel. Putnam’s first two assignments of error are claims of ineffective assistance of counsel. He assigns his trial counsel was ineffective for failing to advocate for or negotiate a plea agreement and for advising him to waive his right to testify at trial. 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. State v. Clark, supra. However, the fact that an ineffective assistance of counsel claim is raised on direct appeal does not necessarily mean that it can be resolved. Id. The determining factor is whether the record is sufficient to adequately review the question under the standard of review previously noted. Id. 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. Id. Generally, 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. State v. Clark, supra. 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. Id.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
State v. Golyar
301 Neb. 488 (Nebraska Supreme Court, 2018)
State v. Figures
308 Neb. 801 (Nebraska Supreme Court, 2021)
State v. Earnest
315 Neb. 527 (Nebraska Supreme Court, 2023)
State v. Tvrdy
315 Neb. 756 (Nebraska Supreme Court, 2024)
State v. Clark
315 Neb. 736 (Nebraska Supreme Court, 2024)
State v. King
316 Neb. 991 (Nebraska Supreme Court, 2024)

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Bluebook (online)
State v. Putnam, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-putnam-nebctapp-2025.