State v. Coleman, A-24-414

Marzeanis M. Coleman was charged with multiple felonies, including robbery, first degree assault, and related offenses, for a planned armed robbery of a restaurant, during which a manager was injured and cash was taken.
Coleman filed numerous pretrial motions, including for bond review and for absolute discharge based on alleged speedy trial violations, and represented himself during key stages following two changes in counsel.
The district court found several periods of delay excludable under the speedy trial statute due to Coleman’s own requests for continuance and actions relating to discovery.
Coleman ultimately entered a plea agreement, pleading guilty to attempted robbery (a reduced charge), while the State dismissed other felonies and a misdemeanor.
He was sentenced to 17–18 years’ imprisonment (within statutory limits) and received credit for time served; probation was denied based on the seriousness of the offense and risk of reoffending.
On appeal, Coleman argued denial of his motion for discharge, excessive sentence, and ineffective assistance of counsel.

Issue	Coleman's Argument	State's Argument	Held
Denial of motion for absolute discharge	Speedy trial rights were violated, should have been discharged.	Time delays were excludable; no violation occurred; plea waives defense.	Waived by plea; court won't review.
Excessive sentence	Sentence too harsh given background and minimal criminal history; should have received probation.	Sentence within statutory range; serious offense; prior record; high risk.	No abuse of discretion; sentence affirmed.
Ineffective assistance (meeting/discovery/proffer)	Counsel failed to meet, review discovery, or secure leniency via proffer.	Record refutes claim; Coleman got favorable plea and chose self-rep.	No prejudice or deficient performance shown.
Ineffective assistance (pretrial motions)	Counsel failed to file necessary pretrial motions.	Claims not specific, no particular motions identified.	Insufficiently specific; claim fails.

State v. Chase, 310 Neb. 160 (2021) (standard for reviewing speedy trial dismissals)
State v. Alkazahy, 314 Neb. 406 (2023) (standard for reviewing sentencing discretion)
State v. Wills, 285 Neb. 260 (2013) (discretion in denying probation)
State v. Lierman, 305 Neb. 289 (2020) (standards for ineffective assistance on direct appeal)
State v. Parnell, 305 Neb. 932 (2020) (Strickland test for ineffective assistance)
State v. Mrza, 302 Neb. 931 (2019) (requirement of specificity in IAC claims)