State v. Bol, 294 Neb. 248

In December 2014, Angelo M. Bol shot and killed a co-worker at a meatpacking plant; he later pleaded no contest to first-degree murder and was sentenced to life imprisonment.
Police questioned Bol at the scene and at the jail; Bol spoke English during a brief booking and a 2-hour interview, signed a Miranda waiver, and never said he did not understand questions.
Bol is Sudanese; his native language is Dinka Bor. An interpreter who appeared at the jail was not used because officers concluded Bol could communicate in English.
At the plea hearing the court explained rights, the nature of the charge, and that first-degree murder is punishable by life imprisonment; Bol repeatedly expressed some difficulty understanding the process but ultimately pled no contest.
Bol moved to suppress statements and later appealed, arguing his plea was involuntary, the court should have appointed an interpreter, he was not informed of the penalty range, and trial counsel was ineffective for not securing an interpreter or ensuring comprehension.

Issue	Bol's Argument	State's Argument	Held
Whether plea was made knowingly, voluntarily, intelligently	Bol: Did not understand proceedings or rights; plea involuntary	State: Record shows court advised rights and factual basis; Bol demonstrated comprehension	Court: Plea voluntary; court adequately informed Bol and found factual basis
Whether court erred by not appointing an interpreter sua sponte	Bol: Language difficulty required interpreter to protect due process and Sixth Amendment rights	State: Bol and counsel never requested one; record shows sufficient English comprehension	Court: No abuse of discretion; record demonstrates Bol could understand and communicate in English
Whether court failed to inform Bol of penalty range for first-degree murder	Bol: Prosecutor should have stated minimum and maximum	State: First-degree murder (Class IA) punishment is life imprisonment — no separate min/max to explain	Court: No error; Bol knew the penalty (life) and was properly advised of immigration consequences
Whether counsel was ineffective for failing to secure interpreter/ensure understanding	Bol: Counsel should have requested interpreter, stopped the hearing, ensured comprehension	State: Record shows Bol comprehended; counsel’s performance not deficient	Court: No ineffective assistance; record permits review and shows sufficient command of English

State v. Topete, 221 Neb. 771, 380 N.W.2d 635 (Neb. 1986) (trial court’s appointment of interpreter reviewed for abuse of discretion)
State v. Ortega, 290 Neb. 172, 859 N.W.2d 305 (Neb. 2015) (court must advise defendant of constitutional rights to support valid plea)
Perovich v. United States, 205 U.S. 86 (U.S. 1907) (discretionary nature of interpreter appointment in criminal proceedings)