State v. Haynie, 9 N.W.3d 915

Jmaun D. Haynie was convicted of first degree murder (felony murder), second degree assault, and two counts of use of a firearm in connection with a drug deal shooting in Omaha, Nebraska.
The prosecution's central evidence included texts arranging a marijuana deal, eyewitness testimony from a surviving victim, physical evidence, and Haynie’s incriminating social media messages.
During trial, two incidents involving victim's family members (an "outburst" by the victim's mother and a spectator’s memorial T-shirt) occurred in court.
Haynie moved for a mistrial, arguing these incidents prejudiced the jury, and further argued for polling/jury admonishment due to the T-shirt.
Haynie also challenged the sufficiency of evidence for felony murder and argued his proposed jury instruction on aiding and abetting (clarifying "mere presence" is not enough) should have been given.
The trial court denied all post-trial motions and entered convictions and consecutive sentences for Haynie, who appealed directly to the Nebraska Supreme Court.

Issue	Haynie's Argument	State's Argument	Held
Denial of motion for mistrial (outburst, T-shirt)	Outburst and memorial T-shirt were inherently/prejudicially influenced jury	No evidence jury saw/heard incidents; incidents brief and remedied	No abuse of discretion; no actual or inherent prejudice shown
Failure to poll/admonish jury after T-shirt incident	Court was required to poll jurors and admonish re: T-shirt to ensure impartiality	No such requirement; incidents not shown to have reached jury; Haynie did not request	No error; polling/admonishment not required without exposure
Refusal to give "mere presence" aiding & abetting instruction	Instruction necessary so jury won't convict for mere presence/acquiescence	Nebraska pattern instruction covers intent adequately; extra language would confuse	No error; pattern instruction sufficient, proposed would mislead
Sufficiency of evidence for felony murder conviction	Insufficient evidence of intent to rob or knowledge of codefendant's intent	Evidence supports intent and aiding/abetting (actions, statements, texts)	Sufficient evidence; conviction affirmed

State v. Iromuanya, 282 Neb. 798 (guidance on spectator conduct and when juror admonishments may be necessary)
State v. Glantz, 251 Neb. 947 (upholding pattern aiding and abetting instruction; "mere presence" language not needed)
State v. Ely, 287 Neb. 147 (explaining felony murder intent is established by intent to commit the underlying felony)