State v. Hatfield, 933 N.W.2d 78

Steven J. Hatfield was convicted in Gage County of misdemeanor DUI; he appealed through the district court to the Nebraska Supreme Court.
The district court initially reversed based on Birchfield v. North Dakota, but the Nebraska Supreme Court held the good‑faith exception applied to Hatfield’s pre‑Birchfield warrantless blood draw, remanding the case for consideration of Hatfield’s original claims.
Relevant to the remand, the county court entered a discovery order (June 29, 2015); the State had earlier provided 51 pages of materials and indicated other evidence was available for inspection.
On November 4, 2015, Hatfield filed a "Sixth Motion in Limine" asserting the State failed to disclose a witness list, the hospital CLIA certificate, and Nebraska Admin. Code title 177; he sought exclusion of related testimony and documents.
The county court denied the motion; Hatfield never moved to compel or requested a continuance (despite multiple opportunities and an offered continuance at trial and sentencing); trial proceeded and a certified copy of the prior DUI conviction was offered at trial.
The district court affirmed the county court’s rulings on the discovery and sentencing issues on remand; Hatfield appeals to the Nebraska Supreme Court, which affirms.

Issue	Hatfield's Argument	State's Argument	Held
Admission of evidence not disclosed under the court discovery order and § 29‑1912 (witness list, CLIA certificate, title 177)	State failed to provide required witness list and documents; undisclosed witnesses and documents should be excluded	State provided substantial discovery earlier (51 pages), identities were available, continuance is preferred cure, Hatfield never sought continuance or motion to compel, and no prejudice shown	Affirmed — no abuse of discretion; exclusion not required; Hatfield waived relief by not seeking continuance and failed to show prejudice
Use of prior conviction for sentence enhancement (alleged nondisclosure)	Prior conviction was not disclosed sufficiently before sentencing; sentence enhancement improper	Driver’s abstract showing the prior conviction was provided in discovery; certified copy available and offered at trial; continuance offered and declined; no prejudice	Affirmed — prior conviction sufficiently disclosed; sentencing not in error

Birchfield v. North Dakota, 579 U.S. 438 (U.S. 2016) (Supreme Court decision addressing warrantless blood draws and related constitutional limits)
State v. Hatfield, 300 Neb. 152, 912 N.W.2d 731 (Neb. 2018) (prior Nebraska Supreme Court decision addressing admissibility of Hatfield’s blood test under the good‑faith exception)
State v. Russell, 292 Neb. 501, 874 N.W.2d 8 (Neb. 2016) (discusses trial court discretion in discovery sanctions and preference for continuance)
State v. Smith, 292 Neb. 434, 873 N.W.2d 169 (Neb. 2016) (addresses remedies for discovery violations and waiver when defendant declines continuance)