State v. Hansen, 855 N.W.2d 777

Hansen conspired with Torres to burn a house owned by a friend and insured; house owned via an LLC, Hansen not a member but associated with the enterprise.
Torres testified that Hansen paid him for starting the fire by buying household goods; a shopping trip to Norfolk followed the fire.
Insurance proceeds were split between Johnston (the insured’s associate) and Hansen, with Hansen not paying Torres the $1,000 allegedly promised.
Torres eventually confessed; Hansen was convicted at bench trial of arson in the second degree, conspiracy to commit arson, and aiding the consummation of a felony.
Court of Appeals reversed Hansen’s aiding-consumption conviction, holding the evidence insufficient; the Supreme Court granted review to address statutory interpretation and sufficiency.
The Supreme Court held that the State proved Hansen intentionally aided Torres in profiting from a felony and reversed in favor of a conviction for aiding the consummation of a felony.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence suffices to convict aiding the consummation of a felony	State argues §28-205(1) broad enough to cover profiting from a felony	Hansen contends aiding-consumation requires more direct linkage to proceeds	Yes; sufficient beyond a reasonable doubt
Meaning of 'proceeds of' and 'profits from' in §28-205(1)	Proceeds/profits extend beyond insurance proceeds to other forms of payoff	Proceeds limited to funds from the felonious act	Broader interpretation; 'profit' as verb includes returns from a transaction
Compatibility of arson conviction with aiding-consumption conviction	Aiding-consumption is a distinct post-felony conduct	Could be seen as duplicative or redundant	Not incompatible; different conduct and elements; both valid
Scope of the aiding-consumption statute in relation to the underlying felony	Statute focuses on aiding in profiting from the felony	Interpretation would render the statute superfluous	Statute meaningful; aiding can occur after felony and relate to profits from it

State v. Robbins, 253 Neb. 146 (1997) (definition of 'proceeds' and related concepts in profit language)
Dean v. State, 288 Neb. 530 (2014) (statutory interpretation principles for plain meaning)
Unisys Corp. v. Nebraska Life & Health Ins. Guar Assn., 267 Neb. 158 (2004) (background on financial concepts in statutory context)
Vlach v. Vlach, 286 Neb. 141 (2013) (statutory-interpretation framework and plain meaning)
State v. Filholm, 287 Neb. 763 (2014) (appellate review of sufficiency of the evidence)