State v. Walker

Nebraska Supreme Court·Decided July 31, 2026·No. S-25-761·Published

Opinion

Nebraska Supreme Court Online Library www.nebraska.gov/apps-courts-epub/ 07/31/2026 08:19 AM CDT

- 940 -

Nebraska Supreme Court Advance Sheets 321 Nebraska Reports

STATE v. WALKER Cite as 321 Neb. 940

State of Nebraska, appellee, v. Louis M. Walker, appellant.

___ N.W.3d ___

Filed July 31, 2026. No. S-25-761.

1. Speedy Trial: Appeal and Error. When reviewing a trial court’s computation of the time a criminal defendant must be brought to trial under Neb. Rev. Stat. §§ 29-1207 and 29-1208 (Reissue 2016), an appellate court reviews the trial court’s factual determinations and supporting specific findings pertaining to the exceptions listed in § 29-1207(4)(a) through (f) for clear error. However, the proper interpretation of § 29-1207(4) and its application to the undisputed historical facts of a case are questions of law. 2. Judgments: Statutes: Appeal and Error. When an appeal calls for statutory interpretation or presents questions of law, an appellate court must reach an independent, correct conclusion irrespective of the determination made by the court below.

3. Speedy Trial. The 6-month period within which an accused is to be brought to trial refers to a period of 6 calendar months, not 180 days. 4. Speedy Trial: Complaints: Indictments and Informations. For cases commenced with a complaint in county court but thereafter bound over to district court, the 6-month statutory speedy trial period does not commence until the filing of the information in district court.

5. Speedy Trial: Indictments and Informations: Probable Cause:

Waiver. For cases commenced with a direct information, one filed initially in district court, the 6-month statutory speedy trial period does not commence until the information is deemed filed, either after an order is entered finding probable cause or the day the defendant waives the preliminary hearing. 6. Speedy Trial. A claimed denial of statutory speedy trial rights involves a relatively simple mathematical computation of whether the 6-month speedy trial clock, as extended by statutorily excludable periods, has expired prior to the commencement of trial.

Nebraska Supreme Court Advance Sheets 321 Nebraska Reports

STATE v. WALKER Cite as 321 Neb. 940

7. ____. To calculate the time for speedy trial purposes, a court must exclude the day the period commenced, count forward 6 months, back up 1 day, and then add any time excluded under Neb. Rev. Stat. § 29-1207(4) (Reissue 2016) to determine the last day the defendant can be tried. The excluded periods are likewise computed by excluding the day of the act, event, or default after which the designated period of time begins to run. 8. Speedy Trial: Proof. When a defendant claims that he or she is entitled to absolute discharge under Neb. Rev. Stat. § 29-1208 (Reissue 2016), the State bears the burden to show, by a preponderance of the evidence, the applicability of one or more of the excluded time periods under Neb. Rev. Stat. § 29-1207(4) (Reissue 2016). 9. Speedy Trial: Indictments and Informations. When the State dismisses an information and later files another, the tacking-and-tolling approach applies.

10. Speedy Trial: Indictments and Informations: Lesser-Included Offenses. Under the tacking-and-tolling approach, the time between dismissal of an information and refiling is not includable, or is tolled, for purposes of the statutory 6-month period. However, any nonexcludable time that passed under the original information is tacked onto any nonexcludable time under the refiled information, if the refiled information alleges (1) the same offense charged in the previously dismissed information , (2) an offense committed simultaneously with a lesser-included offense charged in the information previously dismissed by the State, or (3) commission of a crime that is a lesser-included offense of the crime charged in the previously dismissed information.

11. Speedy Trial: Pretrial Procedure. The plain terms of Neb. Rev. Stat.

§ 29-1207(4)(a) (Reissue 2016) dictate the exclusion of all time between the filing of a defendant’s pretrial motion and the final disposition of such motion, regardless of the promptness or reasonableness of the delay of disposition.

12. ____: ____. The period excludable under Neb. Rev. Stat. § 29-1207(4)(a)

(Reissue 2016) for a defendant’s pretrial motion commences on the day immediately after the filing of a defendant’s pretrial motion and ends at final disposition, which occurs on the date the motion is granted or denied.

13. Judgments: Speedy Trial: Appeal and Error. Generally, a trial court’s determination as to whether charges should be dismissed on speedy trial grounds is a factual question which will be affirmed on appeal unless clearly erroneous.

14. Judgments: Time. Determining whether a court disposed of a motion on a specific date is a question of fact.

Nebraska Supreme Court Advance Sheets 321 Nebraska Reports

STATE v. WALKER Cite as 321 Neb. 940

15. Judges: Evidence. Comments by the trial judge are not evidence. 16. Pretrial Procedure. It is not the parties’ actions that dispose of a motion for discovery, but the court’s order granting or denying it.

17. Speedy Trial: Waiver: Motions for Continuance. A defendant permanently waives his or her statutory speedy trial rights under Neb. Rev. Stat. § 29-1207(4)(b) (Reissue 2016) when an ultimately unsuccessful motion for discharge results in the continuance of a timely trial to a date outside the statutory 6-month period, as calculated on the date the motion for discharge was filed.

Appeal from the District Court for Douglas County: Todd O. Engleman, Judge. Affirmed.

Thomas C. Riley, Douglas County Public Defender, and Christine A. Mori for appellant.

Michael T. Hilgers, Attorney General, and Stacy M. Foust for appellee.

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

Bergevin, J.

INTRODUCTION

In 2004, the State charged Louis M. Walker with two counts of murder in the first degree. That case was dismissed in 2005, but the State refiled the same charges in 2025. Walker appeals from the district court’s denial of his motion for discharge under Neb. Rev. Stat. § 29-1208 (Reissue 2016). At issue on appeal is the district court’s finding that a discovery motion filed by Walker in 2004 was not disposed of before the case was dismissed in 2005. We conclude that the district court did not err by overruling Walker’s motion to discharge and affirm.

BACKGROUND 2004 Information

On June 29, 2004, the State charged Walker by information in the district court for Douglas County with two counts of

Nebraska Supreme Court Advance Sheets 321 Nebraska Reports

STATE v. WALKER Cite as 321 Neb. 940

murder in the first degree. Walker filed a motion for mutual and reciprocal discovery (discovery motion) on July 2, with a notice of hearing the next day—July 3. The record does not contain a journal entry or judge’s notes for a hearing on July 3, or a written order disposing of Walker’s discovery motion.

Judge’s notes from September 1, 2004, indicate that the district court held a pretrial hearing for Walker’s case, where Walker’s counsel informed the court that he intended to file a pretrial motion. Accordingly, the court set Walker’s motion for hearing on January 14, 2005, and scheduled a jury trial to begin on April 18.

On December 27, 2004, the district court held a hearing during which the court remarked that Walker’s counsel had neglected to file a pretrial motion as he informed the court on September 1 he would do. Walker’s counsel acknowledged this oversight and contended that, as a result, the speedy trial clock was not stopped. He then orally made several pretrial motions on the record. The court commented that “if these motions are not timely today for some reason, then of course [speedy trial] will have run on the 29th [of December].” Walker filed his pretrial motions the same day.

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