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249 Neb. 1

541 N.W.2d 380

State v. LeGrand

Nebraska Supreme Court

Decided December 22, 1995

Nebraska Supreme Court · decided 1995-12-22

Applies 18 U.S.C. § 924

Relies on Custis v. United States

Good law ✅— No negative treatment on recordhow we know

Decided 1995-12-22

How this case has been cited

Cited by 53 later decisions — most recently January 2022 · most notably State v. Louthan (1999), State v. Orduna (1996)

53 state decisions

3501995200020102020decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

Wright, J.,

¶1concurring.

¶2I concur in the result of the majority’s opinion, which denied LeGrand’s petition to invalidate his prior convictions. I would not adhere to a decision that would permit a defendant to stall sentence enhancement proceedings by a collateral attack of the prior convictions used for sentence enhancement on the basis that such convictions were not freely, voluntarily, knowingly, and intelligently made. In my opinion, enhancement proceedings should continue independent of any separate proceeding that the defendant brings. The enhancement proceedings should not be placed in limbo for years, pending resolution of such a separate proceeding.

¶3In Custis v. U.S., _U.S._, 114 S. Ct. 1732, 128 L. Ed. 2d 517 (1994), the Court granted certiorari to determine whether a defendant in a federal sentencing proceeding may collaterally attack the validity of previous state convictions that are used to enhance his sentence under the Armed Career Criminal Act, 18 U.S.C. § 924(e) (1994). The Court held that the defendant had no such right to collaterally attack prior convictions, except convictions obtained in violation of the right to counsel. On the basis of Custis, I would not permit a defendant to collaterally attack prior convictions in order to stall an enhancement proceeding.

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