State v. Taylor, 840 N.W.2d 526

Taylor pled guilty to DUI in Lancaster County; enhancement sought based on three prior DUI convictions (1999, 2001, 2002).
State sought to classify current DUI as fourth offense under Neb. Rev. Stat. § 60-6,197.02 (Reissue 2010).
Enhancement hearing relied on exhibits: certified records for 1999 and 2001, and surrogate exhibits for 2002 (exhibits 1, 2, and 5).
Exhibit 1 and Exhibit 5 showed a March 17, 2002 citation date but did not state a precise offense date; Exhibit 2 contained the bill of exceptions.
District court found the State proved the 2002 offense occurred within 12 years of the 2011 offense based on the records and testimony.
Court of Appeals affirmed; Taylor sought further review challenging sufficiency of the evidence to prove the 2002 conviction date.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether exact offense date must be proven for a prior DUI conviction.	Taylor argues exact date is required.	State contends date not required if within 12-year window.	Exact date not required; preponderance shows 12-year window within range.
Whether the exhibits 1, 2, and 5 adequately prove the 2002 DUI conviction.	Taylor objected to Exhibits 1 and 5 on foundation/relevance; not properly challenged on appeal.	Exhibits together establish prior conviction; admissible as prima facie proof.	Exhibits 1, 2, and 5 sufficiently establish the 2002 conviction for enhancement.

State v. Linn, 248 Neb. 809 (1995) (principles for determining prior offenses for sentencing)
State v. Garcia, 281 Neb. 1 (2011) (burden-shifting framework in enhancement proceedings; preponderance standard)
State v. Dreimanis, 258 Neb. 239 (1999) (precedent on enhancement burden)
State v. Copple, 224 Neb. 672 (1987) (earlier framework on sentencing and prior convictions)