State v. Wal, 923 N.W.2d 367

Angok B. Wal pled guilty to criminal mischief (Class IV felony) and a concurrent Class I misdemeanor; sentenced to 20 months’ imprisonment and 12 months’ post-release supervision on the felony, concurrent 12 months on the misdemeanor.
Wal was released and began post-release supervision on July 3, 2017, but absconded after 14 days and violated multiple supervision conditions (missed appointments, testing, treatment, community service, and fees).
The State filed a motion to revoke post-release supervision; Wal admitted the violations and a warrant was issued when he failed to appear initially.
On revocation, the district court imposed 8 months’ imprisonment in the county jail to be served after revocation of post-release supervision.
Wal appealed, arguing the 8-month term, combined with the 20 months he already served, produced a total of 28 months’ imprisonment—exceeding the 24-month statutory maximum for a Class IV felony.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether imposition of 8 months after revocation exceeded the statutory maximum for the underlying Class IV felony	Wal: combining pre-revocation imprisonment and post-revocation imprisonment cannot exceed § 28-105 maximum (24 months)	State: § 29-2268(2) authorizes imprisonment up to the remaining period of post-release supervision, independent of § 28-105 limits	Court: § 29-2268(2) governs revocation terms exclusively; court may impose up to remaining supervision period regardless of original § 28-105 maximum

State v. Ralios, 301 Neb. 1027 (clarifying statutory interpretation principles)
State v. McGuire, 301 Neb. 895 (discussing statutory construction and post-release supervision context)
State v. Kennedy, 299 Neb. 362 (defining post-release supervision and interpreting revocation consequences)