State v. Knight, 311 Neb. 485

Knight was convicted of assault by a confined person (Class IIIA felony) and sentenced to 1 year imprisonment followed by 18 months of post-release supervision (PRS).
After completing the prison term, Knight was released on PRS; ten months later the State moved to revoke PRS and Knight admitted the violations.
The district court revoked PRS and resentenced Knight to 9 months in the Buffalo County Jail, gave 27 days credit for time already served, and expressly found he did not qualify for future “good time” credit.
Knight appealed solely on the ground that the court lacked authority to deny county jail good time under Neb. Rev. Stat. § 47-502; the State agreed on appeal.
The Nebraska Supreme Court held the denial of good time was contrary to law, vacated that portion of the sentence, remanded with directions, and affirmed the remainder of the sentence.

Issue	Knight's Argument	State's Argument	Held
Whether a sentencing court may categorically deny county jail good‑time credit when resentencing a person to county jail after revocation of post‑release supervision	Denial violates § 47‑502 because the court ordered county jail confinement, so Knight must be eligible for good‑time credit	Agreed with Knight on appeal (no statutory authority to deny good time on revocation sentences to county jail)	Court held § 47‑502 unambiguously requires good‑time eligibility for county jail confinement after PRS revocation; denial was contrary to law, vacated and remanded

State v. Lobato, 259 Neb. 579 (2000) (rejected denial of county jail good time in probation context)
Williams v. Hjorth, 230 Neb. 97 (1988) (applied § 47‑502 to pre‑sentence county jail confinement)
State v. Taylor, 310 Neb. 376 (2021) (interpreting mandatory sentencing duties and use of “shall”)
State v. Hofmann, 310 Neb. 609 (2021) (statutory use of “include” indicates non‑exhaustive list)
State v. Kantaras, 294 Neb. 960 (2016) (principles of statutory interpretation governing plain language)