State v. Alfredson, 287 Neb. 477

Joshua G. Alfredson was convicted by a jury of first‑degree sexual assault and second‑degree false imprisonment; sentences affirmed on direct appeal.
Alfredson filed a timely postconviction motion raising multiple claims, including ineffective assistance of trial counsel for allegedly failing to communicate plea negotiations.
The district court denied all postconviction claims without evidentiary hearings except the plea‑offer claim, which proceeded to an evidentiary hearing.
At the hearing, Alfredson testified counsel failed to relay a December 16, 2009 courthouse conversation about a possible "zero to five" plea; counsel and the county attorney testified the conversation was not a formal offer and no written terms existed.
The district court found no formal offer was made on December 16 and denied relief; Alfredson appealed, but only the plea‑offer ineffective assistance claim was timely and therefore before the court.

Issue	Alfredson's Argument	State's Argument	Held
Whether appellate court has jurisdiction over all postconviction claims	Alfredson preserved appeal of all claims	State: July 24 order denying most claims was final and appeal was untimely	Only the plea‑offer claim was timely; court lacked jurisdiction over other claims
Whether trial counsel was ineffective for failing to communicate a plea offer	Counsel failed to inform Alfredson of a December 16 plea proposal; that deficiency prejudiced Alfredson under Strickland	No formal offer was made on Dec. 16; conversation was preliminary and not authorized, so counsel was not deficient	No clear error in district court finding no formal offer; counsel not ineffective for failing to disclose it

Strickland v. Washington, 466 U.S. 668 (ineffective assistance two‑part test)
Missouri v. Frye, 132 S. Ct. 1399 (duty to communicate formal plea offers)
State v. Alfredson, 282 Neb. 476 (direct appeal decision)
State v. Iromuanya, 282 Neb. 798 (counsel’s failure to communicate plea offer as deficient under prior Neb. precedent)
State v. Vanderpool, 286 Neb. 111 (postconviction burden and Strickland application)