State v. Wright

33 Neb. Ct. App. 929
CourtNebraska Court of Appeals
DecidedJanuary 13, 2026
DocketA-25-031
StatusPublished

This text of 33 Neb. Ct. App. 929 (State v. Wright) 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. Wright, 33 Neb. Ct. App. 929 (Neb. Ct. App. 2026).

Opinion

Nebraska Supreme Court Online Library www.nebraska.gov/apps-courts-epub/ 01/20/2026 08:11 AM CST

- 929 - Nebraska Court of Appeals Advance Sheets 33 Nebraska Appellate Reports STATE V. WRIGHT Cite as 33 Neb. App. 929

State of Nebraska, appellee, v. Patrick L. Wright, appellant. ___ N.W.3d ___

Filed January 13, 2026. No. A-25-031.

1. Rules of Evidence. In proceedings where the Nebraska Evidence Rules apply, the admissibility of evidence is controlled by the Nebraska Evidence Rules; judicial discretion is involved only when the rules make discretion a factor in determining admissibility. 2. Rules of Evidence: Hearsay: Appeal and Error. Apart from rulings under the residual hearsay exception, an appellate court reviews for clear error the factual findings underpinning a trial court’s hearsay rul- ing and reviews de novo the court’s ultimate determination to admit evidence over a hearsay objection. 3. Constitutional Law: Witnesses: Appeal and Error. An appellate court reviews de novo a trial court’s determination of the protections afforded by the Confrontation Clause of the Sixth Amendment to the U.S. Constitution and article I, § 11, of the Nebraska Constitution and reviews the underlying factual determinations for clear error. 4. Sentences: Appeal and Error. An appellate court will not disturb a sen- tence imposed within the statutory limits absent an abuse of discretion by the trial court. 5. Sentences. It is within the discretion of the trial court to impose con- secutive rather than concurrent sentences for separate crimes. 6. Rules of Evidence: Hearsay. For a statement to qualify as an excited utterance, the following criteria must be met: (1) There must have been a startling event, (2) the statement must relate to the event, and (3) the statement must have been made by the declarant while under the stress of the event. 7. Rules of Evidence: Hearsay: Time. The key requirement for an excited utterance is spontaneity, which requires a showing the statements were made without time for conscious reflection. - 930 - Nebraska Court of Appeals Advance Sheets 33 Nebraska Appellate Reports STATE V. WRIGHT Cite as 33 Neb. App. 929

8. Constitutional Law. The analysis of the right to confrontation under Neb. Const. art. I, § 11, is the same as that under the Sixth Amendment to the U.S. Constitution. 9. Constitutional Law: Trial: Rules of Evidence: Hearsay. Where “tes- timonial” statements are at issue, the Confrontation Clause demands that such hearsay statements be admitted at trial only if the declarant is unavailable and there had been a prior opportunity for cross-examination. 10. Constitutional Law: Evidence: Intent. Whether a statement is testi- monial for Confrontation Clause purposes depends on the purpose or expectation of the declarant in making the statement, and the circum- stances surrounding the making of the statement illuminate the purpose or expectation of the declarant. 11. Sentences: Appeal and Error. 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. 12. Sentences. In determining a sentence to be imposed, relevant factors customarily considered and applied are the defendant’s (1) age, (2) men- tality, (3) education and experience, (4) social and cultural background, (5) past criminal record or record of law-abiding conduct, and (6) moti- vation for the offense, as well as (7) the nature of the offense and (8) the amount of violence involved in the commission of the crime. 13. ____. The appropriateness of a sentence is necessarily a subjective judg- ment and includes the sentencing judge’s observation of the defendant’s demeanor and attitude and all the facts and circumstances surrounding the defendant’s life. 14. Sentences: Records. A sentencing court is not required to articulate on the record that it has considered each sentencing factor nor to make spe- cific findings as to the facts pertaining to the factors or the weight given them. 15. Sentences: Appeal and Error. Whether a defendant is entitled to credit for time served and in what amount are questions of law, subject to appellate review independent of the lower court. 16. Sentences. When a court imposes multiple sentences contemporane- ously, whether such sentences are ordered to be served consecutively or concurrently, all available credit for time served under Neb. Rev. Stat. § 83-1,106(1) (Reissue 2024) is applied just once, to the aggregate of all terms imposed.

Appeal from the District Court for Douglas County: Molly B. Keane, Judge. Affirmed. - 931 - Nebraska Court of Appeals Advance Sheets 33 Nebraska Appellate Reports STATE V. WRIGHT Cite as 33 Neb. App. 929

Joseph L. Howard and Jason Wendling, Senior Certified Law Student, of Dornan, Howard, Breitkreutz, Dahlquist & Klein, P.C., L.L.O., for appellant. Michael T. Hilgers, Attorney General, and Melissa R. Vincent for appellee. Pirtle, Welch, and Freeman, Judges. Welch, Judge. I. INTRODUCTION Patrick L. Wright appeals from his convictions and sen- tences for possession of a deadly weapon by a prohibited per- son, terroristic threats, and use of firearm to commit a felony. Wright argues that the district court erred in admitting certain evidence over his objections, in imposing excessive sentences, and in finding that Wright knowingly, intelligently, and volun- tarily waived his right to counsel. For the reasons stated herein, we affirm. II. STATEMENT OF FACTS 1. Factual Background On October 3, 2023, law enforcement officers Peter Miller and Andrew Woodard were dispatched to the area of North 21st and Pinkney Streets in Omaha, Nebraska, following a report from Jomo Graham that Wright approached him there in a red two-door Chevy Tahoe and pulled a firearm on him. While heading to the location described by Graham to the 911 emergency dispatch service, officers observed a vehicle match- ing the description heading northbound on Florence Boulevard from Ames Avenue, but the officers continued to the scene. After arriving at the scene, the officers contacted Graham, who was described as “acting very excited. With his speech, he was talking fast. He was animated with his motions.” Officer Miller testified that after a few minutes, Graham pointed “to the east towards Florence Boulevard and sa[id], that’s him right there. At that point, I turn my direction to - 932 - Nebraska Court of Appeals Advance Sheets 33 Nebraska Appellate Reports STATE V. WRIGHT Cite as 33 Neb. App. 929

where he’s pointing and I see the same vehicle that Officer Woodard and I had saw at Florence Boulevard and Ames, a two-door Chevy 1500.” Thereafter, Officers Logan Moran and Erin Riley, who recently arrived at the scene, began fol- lowing the Chevy Tahoe. After making visual contact with the Tahoe, Officer Moran continued to follow it but was directed not to perform a traffic stop. Eventually, Officer Moran “disengage[d]” and other law enforcement officers in unmarked cruisers took over surveillance of the Tahoe. Multiple officers, including Sgt. Jacob Chong, Det. Andrew Ramsay, and Officer Kyle Graber, continued to follow the Tahoe until it cut through a parking lot and pulled over near North 61st and Jaynes Streets. At that time, the officers acti- vated their cruiser lights. Sergeant Chong, Detective Ramsay, and Officer Graber all testified that the Tahoe’s driver, iden- tified as Wright, exited the Tahoe before they exited their cruisers, that Wright faced the officers’ direction, and that Wright was holding a handgun and appeared to be attempting to pull it up.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Wright
33 Neb. Ct. App. 929 (Nebraska Court of Appeals, 2026)

Cite This Page — Counsel Stack

Bluebook (online)
33 Neb. Ct. App. 929, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-wright-nebctapp-2026.