State v. Elseman, 841 N.W.2d 225

Elseman was convicted in Douglas County for first degree murder and use of a deadly weapon during a felony arising from a July 6, 2011 shooting during an attempted robbery.
Emily provided key testimony about the plan to rob Winters and the text messages sent around the time of the shooting.
Evidence included text messages from Emily’s and Elseman’s phones and testimony from officers about data retrieved from Emily’s phone.
The State sought to authenticate text-message content despite the absence of direct authentication for who sent the messages.
Elseman moved for directed verdict on felony murder and use of a deadly weapon; the district court denied these, and the jury returned guilty verdicts.
Elseman argues the trial court erred in admitting text-message content and in denying directed verdict; the State cross-appears with standard sufficiency review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Text-message authentication	Elseman challenges authentication of text messages.	Elseman contends content was not properly authenticated.	Rule 901 satisfied; admissible text messages.
Directed verdict on felony murder and weapon	State argues sufficient evidence; directed verdict improper.	Elseman asserts insufficient or improperly directed verdict.	No error; motions for directed verdict overruled.
Sufficiency of evidence	Evidence supports intent to rob and causal link to murder.	Insufficient evidence of essential elements.	Evidence sufficient to sustain convictions.

State v. Nolan, 283 Neb. 50 (2012) (auth/abuse of discretion standard for authentication rulings)
State v. Eagle Bull, 285 Neb. 369 (2013) (directed-verdict standard; any evidence can preclude)
State v. Taylor, 282 Neb. 297 (2011) (Rule 901 authentication not high hurdle)
State v. Pullens, 281 Neb. 828 (2011) (e-mails authentication; contents may be circumstantial)
State v. Seberger, 284 Neb. 40 (2012) (sufficiency and directed verdict standard)