State v. Kolbjornsen, 295 Neb. 231

In Sept 2014 Kolbjornsen began serving Nebraska sentences; Hall County later charged him with assault by a confined person and he was bound over to district court.
The 180-day intrastate detainer period under § 29-3805 began Dec 16, 2014, so trial absent tolling had to occur by June 14, 2015.
Kolbjornsen requested a continuance on May 22, 2015; the court continued the trial to Aug 26, adding 96 days and moving the deadline to Sept 18, 2015.
At an Aug 12, 2015 plea hearing the court explained that courtroom renovations made jury-capable courtrooms unavailable for extended periods and that the next available jury date was Dec 16, 2015. Defense counsel said Kolbjornsen did not object to not trying the case in August.
Kolbjornsen filed motions Dec 7, 2015 to dismiss under § 29-1207 and § 29-3805. The district court held an evidentiary hearing, found courtroom unavailability constituted "good cause" to extend time, excluded the relevant periods, and denied dismissal.
The Supreme Court held only § 29-3805 (intrastate detainer statute) applied to an in-state prisoner; it affirmed the district court’s finding that courtroom unavailability established good cause and that the statutory time had not expired when the motions were filed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Which speedy-trial statute governs an in-state prisoner?	Kolbjornsen argued § 29-1207 applied.	State argued intrastate detainer statute § 29-3805 governs committed offenders.	§ 29-3805 governs; § 29-1207 does not apply to in-state prisoners.
Was the 180-day period under § 29-3805 tolled by the May 22 continuance?	Kolbjornsen conceded his May 22 continuance tolled the period (adds 96 days).	State agreed the continuance tolled and extended the deadline.	Continuance tolled the period; new deadline moved accordingly.
Did the Aug 12 plea hearing and subsequent courtroom unavailability constitute "good cause" to further extend the period?	Kolbjornsen contended there was insufficient notice and inadequate proof that courtroom unavailability justified extension.	State argued the court explained facility unavailability on the record and evidence showed no earlier jury-capable dates, so good cause existed.	Court found on record evidence that courtroom unavailability was substantial good cause; extension upheld.
Was dismissal required when motions were filed on Dec 7, 2015?	Kolbjornsen argued the statutory time had expired and dismissal was required.	State argued combined tolling and good-cause extensions kept the deadline open beyond Dec 7.	Time had not expired (extension through Jan 8, 2016); dismissal was not required.

State v. Tucker, 259 Neb. 225 (holding intrastate detainer procedures govern committed offenders)
State v. Ebert, 235 Neb. 330 (discussing applicability of detainer statute to prisoners)
State v. Soule, 221 Neb. 619 (addressing continuance effect under detainer statute)
State v. Huston, 285 Neb. 11 (speedy-trial review standard and continuance issues)
State v. Filholm, 287 Neb. 763 (procedural points on speedy-trial appeals)
State v. Rouse, 13 Neb. App. 90 (Court of Appeals applying detainer continuance principles)
State v. Caldwell, 10 Neb. App. 803 (Court of Appeals on good-cause extensions for prisoners)