State v. Rupp

320 Neb. 502
CourtNebraska Supreme Court
DecidedDecember 12, 2025
DocketS-24-522
StatusPublished
Cited by1 cases

This text of 320 Neb. 502 (State v. Rupp) 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. Rupp, 320 Neb. 502 (Neb. 2025).

Opinion

Nebraska Supreme Court Online Library www.nebraska.gov/apps-courts-epub/ 12/12/2025 08:09 AM CST

- 502 - Nebraska Supreme Court Advance Sheets 320 Nebraska Reports STATE V. RUPP Cite as 320 Neb. 502

State of Nebraska, appellee, v. Kyle L. Rupp, appellant. ___ N.W.3d ___

Filed December 12, 2025. No. S-24-522.

1. Criminal Law: Convictions: Evidence: Appeal and Error. When 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 evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential ele- ments of the crime beyond a reasonable doubt. 2. Appeal and Error. Whether an assignment of error and accompanying argument is too vague to be sufficiently raised before the appellate court is a question of law. 3. Self-Defense. To successfully assert the claim of self-defense, one must have an objectively reasonable and good faith belief in the necessity of using force, and the force used in defense was immediately necessary and justified under the circumstances. 4. Self-Defense: Juries. A defendant’s claim of self-defense is a question of fact for the jury. 5. Effectiveness of Counsel: Appeal and Error. When a defendant’s trial counsel is different from counsel on direct appeal, the defendant must raise on direct appeal any issue of trial counsel’s ineffective perfor- mance which is known to the defendant or is apparent from the record, or else the claim will be procedurally barred. 6. Effectiveness of Counsel: Records: Appeal and Error. The appellate court will determine if the record on appeal is sufficient to review the merits of the ineffective performance claims. 7. Postconviction: Effectiveness of Counsel: Appeal and Error. A motion for postconviction relief asserting ineffective assistance of trial counsel is procedurally barred when (1) the defendant was represented by a different attorney on direct appeal than at trial, (2) an ineffective assistance of trial counsel claim was not brought on direct appeal, and - 503 - Nebraska Supreme Court Advance Sheets 320 Nebraska Reports STATE V. RUPP Cite as 320 Neb. 502

(3) the alleged deficiencies in trial counsel’s performance were known to the defendant or apparent from the record. 8. Appeal and Error. A generalized and vague assignment of error that does not advise an appellate court of the issue submitted for decision will not be considered. 9. Claims: Effectiveness of Counsel. A claim of ineffective assistance of trial counsel that is insufficiently stated is no different than a claim not stated at all and will not prevent the procedural bar accompanying the failure to raise all known or apparent claims of ineffective assistance of trial counsel. 10. Postconviction: Effectiveness of Counsel: Records: Appeal and Error. For the purpose of avoiding a procedural bar to a future post- conviction action, appellate counsel must present the claim with enough particularity 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 be able to recognize whether the claim was brought before the appellate court. 11. ____: ____: ____: ____. While a defendant with new counsel on appeal must make specific allegations of trial counsel’s deficient performance known to the defendant or apparent from the record, the defendant is not required to make detailed factual allegations of prejudice to preserve a claim of ineffective assistance of trial counsel. 12. Effectiveness of Counsel: Records: Appeal and Error. A specific enough description of deficient performance in the assignment of error must, standing alone, permit an appellate court to determine if the claim can be decided upon the trial record and permit a district court to later recognize if the claim was brought before the appellate court. 13. ____: ____: ____. The argument section of the brief is to elaborate on the ineffective assistance of counsel claims by discussing legal authority and its application to the trial record, not to set forth, for the first time, the allegedly deficient act. 14. Effectiveness of Counsel: Appeal and Error. Any claim of ineffective assistance of counsel alleging deficient conduct must be more specific than generalities of inadequate preparation or failures to introduce ben- eficial evidence. 15. ____: ____. Claims of alleged failures by counsel respecting motions must set forth on what grounds a motion should have been made or what information was omitted from a motion that was made. 16. Effectiveness of Counsel: Postconviction: Witnesses: Appeal and Error. When the claim of ineffective assistance on direct appeal involves uncalled witnesses, the defendant must give the names or descriptions of any uncalled witnesses forming the basis of a claim - 504 - Nebraska Supreme Court Advance Sheets 320 Nebraska Reports STATE V. RUPP Cite as 320 Neb. 502

of ineffective assistance of trial counsel; what the witness would have said may be part of the witness’ description when the name is unknown.

Petition for further review from the Court of Appeals, Moore, Bishop, and Welch, Judges, on appeal thereto from the District Court for Scotts Bluff County, Leo P. Dobrovolny, Judge. Judgment of Court of Appeals affirmed.

Jerald L. Ostdiek, of Douglas, Kelly, Ostdiek, Snyder, Ossian & Vogl, P.C., for appellant.

Michael T. Hilgers, Attorney General, and P. Christian Adamski for appellee.

Funke, C.J., Cassel, Stacy, Papik, Freudenberg, and Bergevin, JJ.

Freudenberg, J. I. INTRODUCTION Kyle L. Rupp was convicted by a jury of second degree assault and use of a deadly weapon to commit a felony. He appealed to the Nebraska Court of Appeals, which affirmed. The Court of Appeals found there was sufficient evidence to support the verdicts despite Kyle’s claim of self-defense. Further, it held that all but one of Kyle’s claims of ineffective assistance of trial counsel were insufficiently raised because the assignments of error, read disjunctively from the argument section of the brief, did not provide enough particularity for both (1) a district court reviewing a petition for postconviction relief to be able to recognize whether the claim was raised and preserved on direct appeal and (2) the appellate court on direct appeal to be able to determine if the claim can be decided upon the trial record. As for the remaining claim of ineffec- tive assistance of trial counsel, the Court of Appeals found the record insufficient to review it on direct appeal. We granted further review. - 505 - Nebraska Supreme Court Advance Sheets 320 Nebraska Reports STATE V. RUPP Cite as 320 Neb. 502

II. BACKGROUND 1. Trial The victim, Sherry Clark (Sherry), lived in the same apart- ment complex as Kyle’s cousin, Kayla Rupp. Late one evening in December 2023, Kyle showed up at Kayla’s apartment for an unexpected and unwelcome visit. Kayla testified Kyle was drunk. Using forceful language, Kayla told Kyle, approxi- mately four times, to leave. Kyle refused to do so. The entrance to each apartment was accessible directly from the outdoor common area. Sherry was inside her apartment. She testified she heard screaming and Kayla’s telling someone not to touch her and that she was going to “call the cops.” Kayla testified she went to Sherry’s apartment. Kayla’s phone was broken, and she was going to ask to use a phone to call a family member or the police. Sherry answered the door holding a baseball bat. Sherry told Kayla her phone was not working, explaining at trial it only took incoming calls. Sherry saw a man behind Kayla “marching towards [Sherry’s] door.” According to Sherry, Kyle came close to her door and refused Kayla’s demand that he leave, so Sherry swung the bat toward Kyle’s midsection.

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Cite This Page — Counsel Stack

Bluebook (online)
320 Neb. 502, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-rupp-neb-2025.